EU consultation
17 submissions from 17 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission lists 36 submissions on this file. Shown here: the 17 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.
2 submissions from industry — companies and their trade associations — against 7 from civil society: NGOs, consumer organizations, environmental groups and trade unions.
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
The file, right now
The consultation closed on 25 Mar 2026 — it ran from 25 Feb 2026.
How it got here
Also on the Commission’s pipeline for this file, with no date recorded: Dec impl.
17 positions
· · filed 25 Mar 2026 · source
Air quality – technical details for modelling applications and determination of spatial representativeness of sampling points through free reporting from European citizens directly to a European coordination centre.
Filed in Italian · English published by the European Commission
· · filed 25 Mar 2026 · source
We kindly thank the Commission for providing the possibility to comment on the draft Implementing Act (IA) on modelling and assessing spatial representativeness of sampling points. In general, the draft includes several important issues on the clarification of how modeling and spatial representativeness shall be used by MSs. Please, find below our comments.
This feedback is submitted by Kevin Doshi, Climate Department, Logos Research Centre, an independent policy research think tank. We welcome the direction this decision takes. Making air quality modelling a formal assessment tool is the right move, and the overall framework is broadly sound. That said, we've identified three areas where the current draft falls short of what the directive sets out to achieve.
· · filed 25 Mar 2026 · source
The French authorities are fully in line with the approach aimed at defining common methodologies within the European Union for determining the areas of spatial representativeness of sampling points and the use of modelling, in accordance with the provisions of Article 8 (7) of Directive (EU) 2024/2881.
Filed in French · English published by the European Commission
Eurocities, represented by the working group Air Quality (WG Air), would like to take this opportunity to highlight some remarks/considerations of our members in the document attached. Cities play a central role in the work with local air quality especially with regards to being the areas that most often must fulfil extended obligations in terms of measurements and mitigation plans against excessive air pollution…
Contribution submitted by the LCSQA, the french national reference laboratory on air quality,in consultation with the regional bodies responsible for the operational implementation of air quality monitoring (AASQA - Associations Agréées de Surveillances de la Qualité de lAir) : - General comment : We consider it essential that the IA states clearly that understanding the articulation between measurements, modelling…
EEB, Europes largest network of environmental citizens organisations with over 190 member organisations in 41 countries, welcomes the opportunity to provide feedback on the draft Implementing Act on modelling applications and spatial representativeness of sampling points.
The Health and Environment Alliance (HEAL), the leading not-for-profit organisation addressing how our environment affects health in the European Union and beyond welcomes the opportunity to provide comments. HEAL considers that the Commissions draft implementing act under Article 8 of Directive (EU) 2024/2881, in its form as published on 25 February 2026: 1.
· · filed 25 Mar 2026 · source
CZ supports the text of the Implementing Act on technical details for air quality modelling and for determining the spatial representativeness of sampling points. CZ suggests the following amendments to further clarify the text: Regarding Art. 2 point b), CZ notes that some areas might be heterogenous to the decree that cannot be reflected even in high resolution models.
While we understand that the matter is highly technical we consider that a system that relies on unclear rules becomes the cause of problems rather than solutions. It in facts seems also from the initial comments that have been given to the implementing act that some contrasts exist on the level of the shared scientific knowledge reached in the modeling field.
· · filed 25 Mar 2026 · source
Clean Air in London (CAL) considers that the Implementing Act should encourage high ambition and quality while ensuring robust minimum standards among member states. This requires as much detail as possible in the text e.g. specifying minimum spatial resolution of 10m x 10m in urban areas and 1km x 1km in rural areas.
Dear colleagues, the Transport Alliance for Clean Air (TACA) is a group of companies and organisations from the transport and mobility space that shares a common vision for clean air in the European Union. Our members develop, deploy and scale solutions that reduce harmful emissions and support the EUs ambition towards Zero Air Pollution by 2050.
· · filed 25 Mar 2026 · source
We find that there is a risk of misunderstanding Article 4 point 2. It is possible to misread the meaning that estimating the spatial representativeness of sampling points according to this Art 4 is necessary also for zones where all sampling points are below the assessment threshold. It would be beneficial if the text could be clarified to reduce the risk of misunderstanding.
The comments and textual amendments set out in the document in annex were made following Belgian expert consultations as well as insights gained through consultation with other Member States. The main remark on the draft proposal is that a clear distinction is missing between the use of modelling for calculating the spatial representativeness of sampling points and the use of modelling for assessment/compliance…
· · filed 25 Mar 2026 · source
I propose to add an additional point (vi) to Article 2(c) of the draft Commission Implementing Decision, with the following wording: "are, where possible, based on emission factors and activity data representative of actual operating conditions;" Justification: Adding this provision would allow, in the future, the use of emission factors and activity data reflecting real operating conditions, which may differ from…
As authors of a recent paper on the validation protocol for forecast applications developed within the FAIRMODE community ( http://dx.doi.org/10.5194/gmd-16-6029-2023), and of several papers on spatial representativeness of sampling points(e.g.
· · filed 23 Mar 2026 · source
It is proposed to add an additional point (vi) to Article 2(c) of the draft Commission Implementing Decision, with the following wording: "are, where possible, based on emission factors and activity data representative of actual operating conditions;" Justification: Adding this provision would allow, in the future, the use of emission factors and activity data reflecting real operating conditions, which may differ…
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.