Review of the National Air Pollution Control Programme France...The following report presents the...
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Review of the National Air Pollution Control Programme – France
___________________________________________________ Final Report for European Commission – DG Environment Specific contract 070201/2018/791186/SER/ENV.C.3
ED 11495 | Issue Number 3 | Date 23/03/2020
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Author:
Hetty Menadue
Approved By:
Ben Grebot
Date:
23 March 2020
Ricardo Energy & Environment reference:
Ref: ED11495 - Issue Number 3
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Table of contents
1 Introduction ................................................................................................................ 4
Review of the National Air Pollution Control Programmes ................................................ 4
Methodology ...................................................................................................................... 5
NAPCP submission documents ........................................................................................ 6
2 Projected compliance with NECD emission reduction commitments .................... 8
Margin of compliance ........................................................................................................ 8
Projected compliance and consistency with projections submitted under Article 10(2) .... 9
3 Findings of the in-depth NAPCP review ................................................................. 15
NAPCP overview (M) ...................................................................................................... 15
Executive summary (O) ................................................................................................... 15
The national air quality and pollution policy framework (M, O) ....................................... 15
Progress made by current PaMs in reducing emissions and the degree of compliance with
national and EU obligations, compared to 2005 (M, O) .............................................................. 16
Projected situation assuming no change in currently adopted PaMs (M, O) .................. 17
Policy options considered to comply with emission reduction commitments for 2020 and
2030, intermediate emission levels for 2025 and stakeholder consultation (M, O) .................... 18
The policies selected for adoption by sector including timetable for adoption,
implementation and review and responsible competent authority (M, O) .................................. 23
Projected combined impacts of PaMs on emission reductions, air quality and the
environment and associated uncertainties (where applicable) (M, O) ....................................... 25
4 Conclusions and recommendations ....................................................................... 28
Conclusions ..................................................................................................................... 28
Recommendations .......................................................................................................... 29
Appendices
Appendix 1 Completeness assessment
Appendix 2 Assessment of the risk of non-compliance
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Abbreviations BaP Benzo(a)pyrene
BAT Best Available Technique
BC Black Carbon
CH4 Methane
CO2 Carbon dioxide
EEA European Environment Agency
EU European Union
ETS Emission trading system
GHG Greenhouse Gas
kt Kilo tonne
NAPCP National Air Pollution Control Programme
NECD National Emission reduction Commitments Directive (Directive (EU) 2016/2284)
NECP National Energy and Climate Plans
NFR Nomenclature for Reporting
NH3 Ammonia
NMVOC Non-Methane Volatile Organic Compounds
NO2 Nitrogen dioxide
NOx Nitrogen oxides
O3 Ozone
PaMs Policies and Measures
PM10 Particulate matter 10 micrometres or less in diameter
PM2.5 Particulate matter 2.5 micrometres or less in diameter
RAG Red; Amber; Green [rating]
SO2 Sulphur dioxide
WAM With Additional Measures
WHO World Health Organisation
WM With Measures
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1 Introduction
Review of the National Air Pollution Control Programmes
1.1.1 This report
The following report presents the results of the review of the National Air Pollution Control Programme
(NAPCP) submitted to the European Commission by France on 9 October 2019.
EU Member States are required to prepare and report their NAPCP according to the minimum content
and common format (Commission Implementing Decision (EU) 2018/1522)1 stipulated by Article 6 of
the Directive (EU) 2016/2284 on the reduction of national emissions of certain atmospheric pollutants2,
hereafter referred to as the Directive or the NECD3. The NAPCP should demonstrate compliance with
the Member State’s respective emission reduction commitments and set out how compliance will be
achieved.
This review has been undertaken alongside a review of national air pollutant emission projections
developed and reported by Member States under Article 10(2) of the NECD. These reviews have been
commissioned by the European Commission as Service Request 2 under the Framework Contract No
ENV.C.3/FRA/2017/0012 (specific contract 070201/2018/791186/SER/ENV.C.3).
The review of the first NAPCPs and of the air pollution projections with regards to their fulfilment of the
requirements of the NECD will both contribute to the Commission’s reporting on the implementation of
the NECD required under Article 11 of the NECD.
This report feeds into the horizontal review report under the contract which presents conclusions and
recommendations from the review at the EU-level. The horizontal report also contains, for each Member
State, an assessment of its risk of non-compliance with its emission reduction commitments, based on
a cross-analysis of the information provided in the NAPCPs and projection submissions under Article
10(2) of the NECD. This risk assessment is also presented in Appendix 2 to the present report, while
details on the methodology for that complete assessment are found in the horizontal report.
1.1.2 Objectives of the NAPCP review
The purpose of the following report is to determine Member State compliance with the requirements of
the NECD. The scope of the NAPCP review includes:
The use of the NAPCP common format.
NAPCP compliance with the minimum content requirements of the Directive (mandatory content
(M)).
The extent to which the optional content requirements (O) of the Directive are reported and what
added value this brings to the quality of the NAPCP.
Consistency between the NAPCP and the information in the air pollutant emission projections
that were due to be submitted by Member States by 15 March 2019.
The extent to which Member States are reliant on additional PaMs (as included in the ‘With
Additional Measures’ (WAM) scenario) to achieve compliance.
1 Commission Implementing Decision (EU) 2018/1522 of 11 October 2018 laying down a common format for national air pollution control
programmes under Directive (EU) 2016/2284 of the European Parliament and of the Council on the reduction of national emissions of certain
atmospheric pollutants, OJ L 256, 12.10.2018, p. 87.
2 Directive (EU) 2016/2284 of 14 December 2016 on the reduction of national emissions of certain atmospheric pollutants, amending Directive
2003/35/EC and repealing Directive 2001/81/EC, OJ L 344, 17.12.2016, p.1.
3 Directive (EU) 2016/2284 repeals and replaces the previous National Emission Ceilings Directive (2001/81/EC) and is generally referred to as the
new NECD or simply the NECD.
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The extent to which the evidence provided on selected PaMs is robust and the level of confidence
it provides that the Member States will achieve their 2020 and 2030 emission reduction
commitments.
The extent to which additional PaMs are put forward in view of wider air quality objectives as
set out in Article 1(2) of the NECD (referring to the objectives of the Ambient Air Quality Directives,
the Union’s long-term objective of achieving levels of air quality in line with the air quality guidelines
of the World Health Organisation (WHO), the Union’s biodiversity and ecosystem objectives
and coherence with climate and energy policy priorities).
The degree of coherence with other plans and programmes in other policy areas,
predominantly the National Energy and Climate Plans (NECP).
Methodology
The key components of the review process are outlined in Figure 1-1. A comprehensive description of
the process, methodology and checks followed are detailed in accompanying review guidelines which
were provided to the NAPCP reviewers responsible for conducting this report.
Figure 1-1 Overview of the NAPCP review methodology
A central review team was used to conduct the initial screening checks. The purpose of the initial
screening was to document Member State submissions in one central data log. For example, the
information recorded includes the date, language and length of the NAPCP submission; accompanying
annexes are similarly reviewed and logged and links to external websites are checked. The initial
checks also record if the Member State uses the NAPCP common format.
The completeness assessment and in-depth review checks are structured according to the section
headings of the NAPCP common format. Together, the review findings inform the extent to which the
NAPCP is compliant with the minimum content requirements, the extent to which evidence is robust
and the level of confidence that the Member State will achieve its commitments.
NAPCP completeness is rated according to a RAG rating (Red, Amber, Green rating as described in
Appendix 1) while the in-depth checks involve a series of questions with pre-defined responses to be
chosen from, designed to systematically determine the robustness and reliability of the evidence
submitted.
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NAPCP submission documents
An overview of the Member State’s NAPCP is presented in the table below. This information was
gathered as part of the NAPCP initial screening.
Table 1-1 Overview of the Member State NAPCP submission documents
Initial screening check Response Additional comment
Was the NAPCP submitted by 1 April 2019? No
The NAPCP was submitted after the
reporting deadline, on 9 October
2019.
Was the common format used? Yes
The common format was used but
the section numbering is not
consistent throughout the NAPCP.
What is the length of the NAPCP? 42 pages
What language is the NAPCP reported in? French
What language is the supporting
documentation reported in? French
How many external documents are
referenced or provided in the NAPCP? 7
Is it possible to identify the required
information in the external documents (i.e. is
the page and chapter reference provided)?
No Page and chapter references are not
provided.
Can all external documents be accessed? Yes
Weblinks are provided for the 7
external information sources
referenced. One of the weblinks does
not work but the report is publicly
available online.
Completeness assessment
A completeness assessment was conducted to identify gaps in reporting according to the minimum
content requirements of the common format (Commission Implementing Decision (EU) 2018/1522).
The completeness assessment also reviewed the extent of reporting of optional content by the Member
State. The results show some gaps in Member State reporting, as presented in Appendix 1 to this
review. To summarise, the NAPCP includes the minimum content required for:
The title and date of the NAPCP, and responsible competent authority and contact details (section
2.1.1 of the NAPCP).
National emission reduction commitments and relevant policy priorities for air quality, climate
change and energy (including energy efficiency and renewable energy), transport, agriculture,
domestic heating and industry, and the responsible authorities involved (section 2.2.1 of the
NAPCP).
Progress made by current PaMs in reducing SO2, NOx, NH3, PM2.5 and PM10 emissions (section
2.3.1 of the NAPCP) and improving air quality (section 2.4.2 of the NAPCP).
Projected emissions and emission reductions with existing measures (section 2.5.1 of the NAPCP).
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Details concerning the PaMs considered in order to comply with the emission reduction
commitments (reported via the EEA-PaM tool).
Impacts on air quality of the PaMs considered (section 2.6.2 of the NAPCP).
Information on the measures relating to agriculture from Annex III, Part 2 to the NECD (section
2.6.3 of the NAPCP).
Information on the PaMs selected for adoption by sector to comply with the emission reduction
commitments (section 2.7.1 of the NAPCP) and an assessment of how selected PaMs ensure
coherence with policy priorities (section 2.7.2 of the NAPCP).
Projected emissions and emission reductions with additional measures (section 2.8.1 of the
NAPCP). The NAPCP emission reduction projections follow downward linear trajectories (section
2.9.2 of the NAPCP). The use of flexibilities is not reported (section 2.9.3 of the NAPCP).
The completeness assessment found gaps in reporting for the following mandatory reporting
requirements:
Progress made by current PaMs in reducing NMVOC emissions was not reported.
The current transboundary impact of national emission sources was reported to be not estimated
(section 2.4.3 of the NAPCP). France shares borders with Andorra, Belgium, Germany, Italy,
Luxembourg, Monaco, Spain, and Switzerland. Information on the current transboundary impact on
these neighbouring countries should be reported in the NAPCP.
The projected impact on improving air quality was reported to be not estimated (section 2.5.2.1 of
the NAPCP). A qualitative description is required of the projected improvements in air quality and
projected further evolution of degree of compliance (WM scenario) with EU air quality objectives for
NO2, PM10, PM2.5 and O3 values and this is missing.
The Member State has reported the following optional content from the NAPCP common format:
A line chart illustrating the emission reductions per pollutant (section 2.3.1 of the NAPCP) and an
indexed line chart showing the evolution of air quality pollutant concentrations (section 2.4.2 of the
NAPCP).
Associated uncertainties for the NAPCP WM projections to meet the emission reduction
commitments for 2020-2029 and 2030 onwards (section 2.5.1 of the NAPCP).
Information on PaMs reported via the EEA PaM-tool and their expected impact on additional
pollutants to those regulated by the NECD (CO2 and PM10) (reported via the EEA-PaM tool).
Measures to reduce NH3 emissions from livestock manure are among the additional PaMs
considered (relating to the optional measures from Annex III Part 2 to the NECD) (section 2.6.3 of
the NAPCP)
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2 Projected compliance with NECD emission
reduction commitments
Margin of compliance
There are several different metrics that can be used to show the “margin of compliance” i.e. the margin
by which compliance with the NECD emission reduction commitments is achieved or missed.
The following two approaches have been used in the overall assessment of NAPCPs and projections
to calculate the margin of compliance:
1. Calculating the difference between an emission reduction commitment and the
projected emission reductions (difference expressed in percentage points) – this
approach is presented in the NAPCP review reports and follows the same approach as required
in the NAPCP format. The emission reduction commitments specified in Annex II of the NECD
are defined as percentage reductions on the 2005 emissions. Projected emissions of pollutants
in 2020 and 2030 are compared to the 2005 emissions to calculate the projected emission
reductions. These projected reductions are then divided by the 2005 emissions to obtain the
projected reductions as a percentage of the 2005 emissions. These percentage reductions are
then compared to the legally binding percentage reduction, with the difference between them
representing the compliance margin expressed as percentage points. As such, negative
percentage points indicate that the emission reduction commitment will not be met.
Figure 2-1 The margin of compliance
Example
A Member State emitted 500 kt of a pollutant in 2005 and had a 20% emission reduction commitment
for 2020. If the 2020 projected emission is 360 kt, the projected emission reduction is 140 kt. This
equates to 28% of 2005 emissions. The projected margin of compliance is 8 percentage points. This
is illustrated in the figure below.
200
250
300
350
400
450
500
550
2005 2010 2015 2020
Emission reduction commitment
(% of 2005 emission)
Compliance margin
Compliance threshold
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2. Calculating the difference between projected emissions and the compliance threshold
(expressed as a percentage of the compliance threshold) – this approach is presented in
the projections review reports and follows the same approach as used in the context of
emissions inventories.
Given that each emission reduction commitment specified in Annex II of the NECD is defined as a
percentage reduction on the 2005 emissions, these two values can be combined to express a
“compliance threshold” i.e. the maximum emission that can be emitted by a Member State from 2020
and 2030 onwards, and still be compliant with the emission reduction commitment for a pollutant.
Projected emissions (under the WM and WAM scenarios) can be compared to the compliance
threshold, and the compliance margin expressed as a percentage of the compliance threshold.
Example
A Member State emitted 500 kt of a pollutant in 2005 and had a 20% emission reduction commitment
for 2020. The maximum the Member State can emit in 2020 to achieve its 2020 emission reduction
commitment (the “compliance threshold”) is 400 kt. If the 2020 projected emission is 360 kt, the
commitment will be met by 40 kt and the projected margin of compliance is 10% of the compliance
threshold.
Mathematically these two approaches are different as they use different reference points. However,
they yield the same conclusions concerning compliance or non-compliance with the NECD
reduction commitments. The largest numerical differences between the two approaches occur when
there are significant differences between the 2005 emissions and the projected emissions for 2020 or
2030 (this is in particular the case for SO2).
The percentage point approach is used in the review of the NAPCP to understand the margin of
compliance between the projected emission reductions presented in the NAPCP and the legally binding
percentage emission reduction commitments (see Section 2.2 of this report).
The results of the projections review and of the assessment of the NAPCPs are brought together in the
risk assessment for individual Member States (see Appendix 2 of this report), using the margin of
compliance expressed as a percentage of the compliance threshold based on projections submitted
under Article 10(2). The methodology for assessing the risk of non-compliance is explained in the
accompanying horizontal review report.
Projected compliance and consistency with projections
submitted under Article 10(2)
Under the WM scenario of the NAPCP (based on 2013 projections), the 2020-29 national
emission reduction commitments are projected to be achieved for all pollutants except NH3. The
2030 onwards commitments are projected to be achieved for NOx only.
Under the WAM scenario of the NAPCP (based on 2016 projections), the 2020-29 national
emission reduction commitments are projected to be achieved for all pollutants. The 2030
onwards commitments are projected to be achieved for NOx, NH3 and PM2.5 only.
Projections submitted by France in 2019 under Article 10(2) of the NECD are different to those
included in the NAPCP. Under the WAM scenario, the differences affect the projected margins
of compliance for SO2 and NMVOC.
The projections presented in this section are derived from the information reported by the Member State
in their NAPCP. France included 2013 projections for the WM scenario and 2016 projections for the
WAM scenario, which leads to inconsistency between these two scenarios, as well as the ones reported
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under Article 10(2). The historical year of the inventory data underpinning the projections was not
reported in either case, however it would be earlier than the year of the projections used. There is
therefore a high risk of projections used in the NAPCP to be highly outdated. The projections in the
NAPCP are different to the projections data submitted separately by the Member State under Article
10(2) of the Directive on 1 October 2019. The differences affect the conclusions on compliance with
emission reduction commitments for some pollutants as well as projected margins of compliance and
are described below according to the two scenarios.
In addition, the emission reductions presented as kilo tonne in the NAPCP are different to the values
calculated from the percentage reduction values presented (when calculated compared to the 2005
baseline). Under both the WM and WAM scenarios, the differences are marginal for all pollutants (the
differences are between 0.2 and 7 kt) except SO2 and NH3. Under the WAM scenario, the differences
are significant for SO2 (a difference of 300 kt in the year 2020) and NH3 (differences of 23, 27 and 26
kt per commitment year). There is no explanation in the NAPCP to justify this discrepancy and so it is
unclear how and why it has occurred. However, for SO2, it is understood that the discrepancy has
occurred as a result of a reporting error (it is not feasible that the emission reductions presented for the
year 2020 are greater than the 2005 baseline year). To ensure consistency with the other Member State
NAPCP reviews conducted, the projected values presented as kilo tonnes in the NAPCP have been
used for this analysis together with the percentage reduction for all pollutants except for the SO2
projections under a WAM scenario for the year 2020 (where the emission reduction presented in Figure
2-3 is the calculated value using the percentage emission reduction).
In Figure 2-2 and Figure 2-3, the emission reductions needed for 2025 are interpolated according to the
2020-29 and 2030 onwards commitments set out in the NECD. Additional information is included to
demonstrate the extent to which the projections meet the Member State commitments (shown, for each
of the pollutants, as the difference expressed in percentage points between the projected emission
reduction described in the NAPCP and the legal commitment). The percentage points do not represent
the extent to which total emissions projected (kt) compare to the emission reduction commitment (in
terms of kt of emissions).
Under the WM scenario, progress towards the 2020-29 emission reduction commitments is as
follows:
SO2 – The projections of SO2 emissions under the WM scenario show that France can comply with
the 2020-29 reduction commitments specified in the NECD with existing measures. In 2020,
compliance with the emissions reduction commitments is projected to be achieved with a margin of
9 percentage points.
NOx – The projections of NOx emissions under the WM scenario show that France can comply with
the 2020-29 reduction commitments specified in the NECD with existing measures. In 2020,
compliance with the emissions reduction commitments is projected to be achieved with a margin of
6 percentage points.
NMVOC – The projections of NMVOC emissions under the WM scenario show that France can
comply with the 2020-29 reduction commitments specified in the NECD with existing measures. In
2020, compliance with the emissions reduction commitments is projected to be achieved with a
margin of 5 percentage points.
NH3 – The projections of NH3 emissions under the WM scenario show that France cannot comply
with the 2020-29 reduction commitments specified in the NECD with existing measures. In 2020,
compliance with the emissions reduction commitments is projected to be missed with a margin of
7 percentage points.
PM2.5 – The projections of PM2.5 emissions under the WM scenario show that France can comply
with the 2020-29 reduction commitments specified in the NECD with existing measures. In 2020,
compliance with the emissions reduction commitments is projected to be achieved with a margin of
22 percentage points.
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Under the WM scenario, progress towards the 2030 onwards commitments is as follows:
SO2 – The projections of SO2 emissions under the WM scenario show that France cannot comply
with the 2030 onwards reduction commitments specified in the NECD with existing measures. In
2030, compliance with the emissions reduction commitments is projected to be missed with a
margin of 9 percentage points.
NOx – The projections of NOx emissions under the WM scenario show that France can comply with
the 2030 onwards reduction commitments specified in the NECD with existing measures. In 2030,
compliance with the emissions reduction commitments is projected to be achieved exactly.
NMVOC – The projections of NMVOC emissions under the WM scenario show that France cannot
comply with the 2030 onwards reduction commitments specified in the NECD with existing
measures. In 2030, compliance with the emissions reduction commitments is projected to be
missed with a margin of 3 percentage points.
NH3 – The projections of NH3 emissions under the WM scenario show that France cannot comply
with the 2030 onwards reduction commitments specified in the NECD with existing measures. In
2030, compliance with the emissions reduction commitments is projected to be missed with a
margin of 17 percentage points.
PM2.5 – The projections of PM2.5 emissions under the WM scenario show that France cannot comply
with the 2030 onwards reduction commitments specified in the NECD with existing measures. In
2030, compliance with the emissions reduction commitments is projected to be missed with a
margin of 1 percentage point.
Projections submitted by France under Article 10(2) of the NECD in 2019 demonstrate non-compliance
with the 2020-2029 emission reduction commitment for NOx and NMVOC whereas the projections in
the NAPCP demonstrate non-compliance with the 2020-2029 emission reduction commitment for NH3
only. Conclusions on the projected compliance with the 2020-2029 emission reduction commitments
for the SO2 and PM2.5 are the same as presented above but the margins are different.
Projections submitted by France under Article 10(2) of the NECD demonstrate non-compliance with the
2030 onwards emission reduction commitment for NOx and NMVOC whereas the projections in the
NAPCP demonstrate non-compliance with the 2030 onwards emission reduction commitment for SO2,
NMVOC, NH3 and PM2.5 (and compliance with the NOx emission reduction commitment).
These differences in conclusions are likely due to the large time difference between the sets of data
used in various scenarios.
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Figure 2-2 Projected attainment of emission reduction commitments (WM scenario used in the NAPCP)
Note: The extent to which the projections meet the Member State commitments is shown, for each of the pollutants,
as the difference expressed in percentage points between the projected emission reduction described in the
NAPCP and the legal commitment. A negative number indicates that a commitment is not met.
As the projections under the WM scenario demonstrate a gap in compliance with the Member State
NECD emission reduction commitments for certain pollutants, the NAPCP includes projections under a
‘With Additional Measures’ (WAM) scenario.
Under the WAM scenario, progress towards the 2020-29 emission reduction commitments is as
follows:
SO2 – The projections of SO2 emissions under the WAM scenario show that France can comply
with the 2020-29 reduction commitments specified in the NECD with additional measures. In 2020,
compliance with the emissions reduction commitments is projected to be achieved with a margin of
11 percentage points.
NOx – The projections of NOx emissions under the WAM scenario show that France can comply
with the 2020-29 reduction commitments specified in the NECD with additional measures. In 2020,
compliance with the emissions reduction commitments is projected to be achieved with a margin of
7 percentage points.
NMVOC – The projections of NMVOC emissions under the WAM scenario show that France can
comply with the 2020-29 reduction commitments specified in the NECD with additional measures.
In 2020, compliance with the emissions reduction commitments is projected to be achieved with a
margin of 6 percentage points.
NH3 – The projections of NH3 emissions under the WAM scenario show that France can comply
with the 2020-29 reduction commitments specified in the NECD with additional measures. In 2020,
compliance with the emissions reduction commitments is projected to be achieved exactly.
PM2.5 – The projections of PM2.5 emissions under the WAM scenario show that France can comply
with the 2020-29 reduction commitments specified in the NECD with additional measures. In 2020,
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compliance with the emissions reduction commitments is projected to be achieved with a margin of
25 percentage points.
Under the WAM scenario, progress towards the 2030 onwards commitments is as follows:
SO2 – The projections of SO2 emissions under the WAM scenario show that France cannot comply
with the 2030 onwards reduction commitments specified in the NECD with additional measures. In
2030, compliance with the emissions reduction commitments is projected to be missed with a
margin of 8 percentage points.
NOx – The projections of NOx emissions under the WAM scenario show that France can comply
with the 2030 onwards reduction commitments specified in the NECD with additional measures. In
2030, compliance with the emissions reduction commitments is projected to be achieved with a
margin of 3 percentage points.
NMVOC – The projections of NMVOC emissions under the WAM scenario show that France cannot
comply with the 2030 onwards reduction commitments specified in the NECD with additional
measures. In 2030, compliance with the emissions reduction commitments is projected to be
missed with a margin of 1 percentage point.
NH3 – The projections of NH3 emissions under the WAM scenario show that France can comply
with the 2030 onwards reduction commitments specified in the NECD with additional measures. In
2030, compliance with the emissions reduction commitments is projected to be achieved exactly.
PM2.5 – The projections of PM2.5 emissions under the WAM scenario show that France can comply
with the 2030 onwards reduction commitments specified in the NECD with additional measures. In
2030, compliance with the emissions reduction commitments is projected to be achieved with a
margin of 5 percentage points.
Projections submitted by France under Article 10(2) of the NECD demonstrate compliance with all the
2030 onwards emission reduction commitments whereas the projections in the NAPCP demonstrate
non-compliance for SO2 and NMVOC. Conclusions on the projected compliance with the emission
reduction commitments for the other years and pollutants are the same as presented above but the
margins are different with smaller margins of compliance projected for all other pollutants.
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Figure 2-3 Projected attainment of emission reduction commitments reported in the NAPCP (WAM
scenario) used in the NAPCP’
Notes: The extent to which the projections meet the Member State commitments is shown, for each of the
pollutants, as the difference expressed in percentage points between the projected emission reduction described
in the NAPCP and the legal commitment. A negative number indicates that a commitment is not met.
The projected emissions of SO2 in 2020 have been calculated based on the percentage emission reduction
presented in the NAPCP to account for a reporting error (the emission reductions presented for the year 2020 are
otherwise greater than the 2005 baseline year).
The projected emissions of NH3 (kt) do not correspond with the percentage emission reductions presented in the
NAPCP (by a difference of 23, 27 and 26 kt per commitment year). Thus, while the projected emission values are
below the emission reduction commitments, the percentage point value shows that France is projected to miss the
2025 commitment. Both values are included in this review report because it is unclear how and why the discrepancy
has occurred.
Further analysis related to the risk of non-compliance, taking into account the information provided in
both the NAPCP and the projections submissions, is presented in Appendix 2.
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3 Findings of the in-depth NAPCP review
NAPCP overview (M)
The NAPCP was submitted on 9 October 2019, after the deadline (1 April 2019).
The NAPCP is compliant with the common format but the section numbering is inconsistently
used.
A working link to access information on the consultation undertaken in preparation of the NAPCP
is provided but dates several years back.
The NAPCP adheres to the common format specified by the Commission Implementing Decision (EU)
2018/1522, pursuant to Article 6 of the NECD. However, the section numbering in the NAPCP is not
consistently aligned with the common format. The NAPCP is made up of one main report (42 pages in
length). The complete submission was made on 9 October 2019. PaMs were also submitted via the
EEA PaM-tool on 9 October 2019.
Of the seven external links provided in the NAPCP, six are in working order. Nonetheless, all external
references are publicly available online and relate to relevant information sources (national policy
documents (emission reductions, energy and agriculture), guidance documents4 and emission
inventories and air quality statistics).
France reports the title and date for its NAPCP and clearly references the competent authority
responsible for it (the Ministry of Environment, Directorate of Energy and Climate). The information
provided in the submitted NAPCP was published as a different document on 10 May 2017.
The NAPCP includes a weblink directing to the consultation process undertaken for the development
of the 2017 document, but no link directly related to the submitted NAPCP. The consultation was not
extended to neighbouring countries and the transboundary impact of its national emissions was not
reported in the NAPCP.
Executive summary (O)
An executive summary is not reported in the NAPCP. According to the information reported, the NAPCP
is summarised separately and a weblink is provided to access the information5. This external
information source has not been reviewed as part of the NAPCP review.
The national air quality and pollution policy framework (M, O)
Climate and energy policy priorities focus on achieving carbon neutrality by 2050 (section 2.2.1
of the NAPCP).
Relevant policy priorities in other sectors are described for agriculture, transport and domestic
heating.
Air quality policy priorities are only reported as EU air quality standards for PM10, PM2.5, NO2, SO2 and
O3. No reference is made to the WHO guideline values. No detail is reported to explain why these
4 The weblink in the NAPCP is not working but the document is available online: CITEPA (2019) Guide des bonnes pratiques agricoles pour
l'amélioration de la qualité de l'air. https://www.ademe.fr/guide-bonnes-pratiques-agricoles-lamelioration-qualite-lair
5 Plan national de réduction des émissions de polluants atmosphériques (PRÉPA), URL: https://www.ecologique-solidaire.gouv.fr/politiques-
publiques-reduire-pollution-lair#e4 [last accessed 26/11/2019].
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pollutants are prioritised but, for NO2, PM10 and O3, in particular, this corresponds to pollutants that
actually present a challenge6.
National climate and energy policy priorities set out in the NAPCP are to achieve carbon neutrality by
2050, to reduce fossil fuel consumption by 40% between 2019 and 2030 (with the aim of closing the
last coal fuelled installation in 2022) and to reduce GHG emissions by 75% in 2050 compared to a 1990
baseline. Multi-annual programming documents are described as facilitating national action to meet
these objectives and include a multi-annual energy programme 2019-2023 and a National Low Carbon
Strategy.
Relevant agriculture policy priorities cover the restricted use of plant protection products and support
for organic agriculture through public procurement contracts. For transport, the policy priorities reported
cover growth of electric vehicle use, carpooling, and cycling. The transport sector is included among
the sectors to achieve carbon neutrality by 2050. To achieve this, France has committed to a ban on
the sales of carbon fossil cars by 2040 and to increase the number of public charging points for electric
vehicles by five-fold by 2022.
Policy priorities included in the NAPCP also cover improved energy efficiency in buildings and
establishing cleaner domestic heating systems.
Policy making, implementation, reporting and monitoring is carried out at national level by the Ministry
of Environment. National ministry departments corresponding to relevant source sectors are also listed
as involved in policymaking and implementation. National research centres and the national
environment agency are also involved with implementation, as well as monitoring and research. The
respective authorities are responsible for coordinating among themselves. Regional and local
authorities are reported as also being involved in policymaking and implementation. Enforcement roles
are not defined in the NAPCP. The NAPCP review finds that the role of the national government
overseeing air pollution matters will likely facilitate coordination between sectors and regions. It also
finds that local involvement in implementation will likely strengthen implementation through more
targeted action.
Progress made by current PaMs in reducing emissions and
the degree of compliance with national and EU obligations,
compared to 2005 (M, O)
3.4.1 Progress made by current PaMs in reducing emissions
Current PaMs as described cover agriculture, domestic heating, industry and transport. Between
2000 and 2017, current PaMs have contributed to SO2, NOx, NH3, PM2.5 and PM10 emission
reductions.
Progress made by current PaMs in reducing emissions is not reported for NMVOC.
Progress achieved by current PaMs is described between 2000 and 2017 for SO2, NOx, NH3, PM2.5 and
PM10. Progress achieved by current PaMs for NMVOC is not reported and the omission is not explained
in the NAPCP7.
Current PaMs are described with respect to the most significant emission reductions achieved between
2000 and 2017. The degree of compliance with national and Union emission reduction legislation in
6 Air pollution country fact sheets 2018: https://www.eea.europa.eu/themes/air/country-fact-sheets/2018-country-fact-sheets [last accessed:
18/07/2019]
7 The NAPCP includes a weblink to an external data source which includes reporting on NNMVOC. The data source has not been reviewed as part
of the NAPCP review. URL: https://www.citepa.org/fr/secten/ [last accessed 26/11/209].
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relation to the current PaMs is not described. At a national level, emissions for these pollutants
decreased between this timeframe, as illustrated in the NAPCP by an indexed chart (2000 = 100). By
sector, the main drivers for emission reductions achieved are described as:
Agriculture: Improvements to the storage of livestock manure and application of organic and mineral
fertilisers have contributed to NH3 emission reductions.
Domestic heating: Improvements to the performance of wood burning boilers have led to emission
reductions of PM2.5 and PM10.
Industry: Emission reductions of SO2 have been led by industry as a result of greater use of
renewable energy and energy saving measures. Compliance with EU legislation has also led to
SO2 emission reductions including reduced sulphur-content in the fuels used and environmental
permitting. Adoption of dust abatement techniques by industry has also led to emission reductions
of PM2.5 and PM10.
Transport: Emission reductions of NOx have been led by transport as a result of abatement
technologies being applied (including, but not exclusively, retrofitting catalytic converters) which
have managed to offset emissions from the increased number of vehicles on the road. Compliance
with EU legislation for vehicle standards has also led to NOx emission reductions.
3.4.2 Progress made by current PaMs in improving air quality
Concentrations are presented in an indexed chart (2000 = 100) which shows improvements to air quality
in France for NO2, PM10 and SO2 between 2000 and 2017. O3 concentrations are reported to have
remained fairly constant in this period.
Exceedances of EU air quality standards are reported for NO2, PM10 and O3 between 2000 and 2017.
No exceedances have been reported for SO2 since 2009. For NO2, the number of non-compliant air
quality zones reportedly fell between 2000 and 2017 from 24 to 12. For PM10, the number of non-
compliant air quality zones reportedly fell between 2007 and 2017 as a result of air quality plans
adopted. The types of PaMs implemented as a result of the air quality plans is not reported in the
NAPCP. For both pollutants, road transport is reported as the main challenge affecting ambient
concentrations. O3 concentrations have not changed significantly over time and continues to present a
challenge.
3.4.3 Current transboundary impact of national emission sources
The transboundary impact of national emission sources is not reported. In view of the shared border
with Italy, Germany, Belgium, Spain, Monaco, Andorra, Switzerland, and Luxembourg, the NAPCP
review finds that a transboundary impact of national emission sources is likely.
Projected situation assuming no change in currently adopted
PaMs (M, O)
As reported in Section 2.2 of this report, the 2020-29 national emission reduction commitments are
projected to be achieved for all pollutants except NH3 under a WM scenario. The 2030 onwards
commitments are projected to be missed for all pollutants under a WM scenario except NOx, for which
it is projected to be achieved exactly, with no margin (section 2.5.1 of the NAPCP).
The information is based on projections developed in 2013. The historical inventory data used to
underpin the projections therefore do not accurately reflect the current PaMs adopted in France at the
time of the NAPCP submission in 2019. This adds to the uncertainty of the projections reported under
the WM scenario.
France has not reported the projected impact on improving air quality under a WM scenario (section
2.5.2 of the NAPCP).
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Policy options considered to comply with emission reduction
commitments for 2020 and 2030, intermediate emission
levels for 2025 and stakeholder consultation (M, O)
France has reported 50 PaMs via the EEA PaM-tool, targeting agriculture, transport, energy
consumption, industry and cross-cutting.
PaMs reported are not additional because they were adopted in past years.
The estimated emission reduction impact has been quantified for 11 PaMs only.
3.6.1 Summary of the information reported
The assessment presented in this section is based on the information reported via the EEA-PaM tool.
Where relevant, it is complemented with the information from the main body of the NAPCP.
France has reported 50 individual PaMs via the EEA-PaM tool covering four sectors (agriculture, energy
supply, industrial processes, and transport) and cross-cutting measures. A summary of the PaMs
reported via the EEA-PaM tool is provided below in separate tables for each of the sectors.
The PaMs are often not described in much detail. There are examples of broad PaM titles and
incoherent implementation periods, which cannot be clarified by the limited PaM descriptions reported.
For example, in the case of one PaM, emission reductions are quantified for the years 2020 and 2025
but implementation is not planned to start until 2028.
Estimated emission reductions are reported at individual PaM level for 11 of the 50 PaMs reported. The
lack of estimated emission reductions is not explained in the majority of cases. The limited information
means that the PaMs are generally assessed in NAPCP review as having low credibility.
Furthermore, the NAPCP review finds that the PaMs reported are not additional because they were
adopted by national law (2017)8,.
For 43 of the 50 PaMs presented in the NAPCP, the information reported via the EEA PaM-tool can be
further used to confirm that the PaMs are indeed existing measures (these 43 PaMs have been reported
via the EEA-PaM tool as included in the WM scenario). Only seven PaMs have been reported as being
used in the WAM scenario9. However, for these seven PaMs the year of adoption is reported as 2017,
thus it is unclear why they have been reported as additional and used in the WAM scenario.
Energy consumption (domestic heating) (7 individual PaMs)
Reduce the sulphur content in domestic heating oil
Support local authorities in setting up alternative pathways to burning green waste
Ban the sale of garden incinerators
Encourage thermal renovations to domestic housing
Raise public awareness on wood burning appliances and of available aid schemes
8 Arrêté du 10 mai 2017 établissant le plan national de réduction des émissions de polluants atmosphériques.
https://www.legifrance.gouv.fr/jo_pdf.do?numJO=0&dateJO=20170511&numTexte=37&pageDebut=&pageFin=
9 For each PaM reported via the EEA PaM-tool, Member States are required to specify which projections scenario the PaM is included in. The
majority of PaMs are expected to be categorised as ‘with additional measures’, however Member States have the option to report ‘with measures’
and ‘not included’.
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Energy consumption (domestic heating) (7 individual PaMs)
Renew heating appliances with more efficient models
Conduct testing for the performance of heating appliances on the market
* The 2017 national legislation includes three further PaMs not reported via the EEA PaM-tool targeted
to the evaluation and reduction of phytopharmaceuticals. These PaMs do not concern emission
reductions.
Industry (6 individual PaMs)
Strengthen regulatory requirements to reduce emissions from the industrial sector (linked to
implementation of EU legislation)
Reduce emissions of volatile organic compounds in the most heavily emitting sectors (conduct a
study to review progress and strengthen implementation of EU regulation accordingly)
Reinforce the general tax on polluting activities on emissions of air pollutants (conduct an inspection
to assess the environmental impact of the system in place)
Test an “air-industry” fund with local authorities
Increase control of industrial installations in the polluted areas as defined by air quality plans
Strengthen the use of emergency measures to limit pollution from industry during peak pollution
periods
Improve the monitoring of classified installations in the most polluted areas
Agriculture (7 individual PaMs) *
Supporting investments to reduce NH3 volatilisation among livestock and during the spreading of
fertilisers
Reduce the volatilisation of NH3 from mineral fertilisers, in particular by reducing their emission
potential, by encouraging their substitution by less emissive fertiliser forms and by adapting the
practices and means through which they are applied (including the verification of the prohibition
against aerial crop spraying)
Limit the burning of agricultural residue as of the 2019-2020 crop year
Mobilising European funding by the regions and drawing up an action plan to control air pollution of
agricultural origin by region
Develop and disseminate good agricultural practices for improving air quality
Pilot projects to disseminate on-farm use of technologies and practices to reduce NH3 and PM2.5
emissions
Reduce the volatisation of NH3 from livestock manure and other organic effluents spread on
agricultural soils
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Cross-cutting measures (11 individual PaMs)
Promote good practices in the area of reducing air pollution and the exposure of the population
Transport (18 individual PaMs)
Road transport
Convergence of taxation between petrol and diesel
Align the tax deductibility regimes between petrol and diesel
Promote the deveopment of mobility plans by businesses and administrations
Encourage cycling (deploy an insurance scheme, financial to support to purchase electric bicycles,
mobility plan targeting bicycle use)
Enforce the use of air quality certificates for restricted vehicle zones
Establish restricted vehicle zones
Renew public vehicles fleet to favour low-emission vehicles
Developing clean fuels infrastructure under the national framework for alternative fuels
Encourage the conversion of the most polluting vehicles and the purchase of cleaner vehicles
Supporting the adoption of new, ambitious European standards [light and heavy duty vehicles] (anti-
pollution standards, consideration of real driving conditions and improvement of the approval
procedure)
Monitor real time road vehicle emissions
Reinforce the roadworthiness testing of vehicles
Non road machinery
Reduce emissions from non road machinery (implementation of Regulation (EU) 2016/1628) and
market surveillance of non-road mobile machinery
National aviation
Energy efficiency measures related to transportation at airports
Implementing action plans for civil aviation and aerodromes to reduce emissions of air pollutants
Inland shipping
Develop the connection of ships and boats at berth and infrastructure for maritime and inland
waterway transport
Establish new low emission maritime zones
Limit sulphur in marine fuels and reinforce fuel quality controls (implementation of EU Directive
2014/94/EU)
Develop a roadmap for reducing pollutant emissions from inland shipping
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Cross-cutting measures (11 individual PaMs)
Simplify the availability of air quality data and develop knowledge on air quality issues
Improve the degree to which air quality is taken into account in other public policies
Monitor and evaluate actions implemented in areas affected by exceedances of European standards
for pollutant concentrations
Improve [air pollutant] emissions inventory
Make the national day for air quality and the national conferences on air quality regular events
Improve knowledge on the origins of pollution and its impact
Identify and evaluate technologies for reducing and controlling emissions of air pollutants
Mobilise intervention appropriations [funding] for air quality (aid to households and businesses, calls
for projects and studies)
Improve air quality projections
Support community engagement in the implementation of Atmospheric Protection Plans (PPAs)
Anticipating the inclusion of non-regulated pollutants
The analysis in this section reviews the PaMs reported as additional by France, focusing only on PaMs
implemented in 2019 or later. Of the 50 total PaMs reported, only 10 are planned for implementation in
2019 or later. Of these, one refers to the implementation of EU Regulation on non-road mobile
machinery (2016/1628) and therefore has also been excluded from the subsequent analysis. Thus, the
focus in this section of the report is on the following nine PaMs:
Reduce the sulphur content in domestic heating oil (regulatory instrument; planned
implementation in 2028)
Ban the sale of garden incinerators (regulatory instrument; planned implementation in 2020)
Supporting investments to reduce NH3 volatilisation among livestock and during the spreading
of fertilisers (planned implementation to start in 2019)
Mobilising European funding by the regions and drawing up an action plan to control air
pollution of agricultural origin by region (implementation planned to start in 2020)
Develop and disseminate good agricultural practices for improving air quality (planned
implementation to start in 2019)
Reduce emissions of volatile organic compounds in the most heavily emitting sectors (conduct
a study to review progress and strengthen implementation of EU regulation accordingly)
(planned implementation to start in 2019)
Encourage the conversion of the most polluting vehicles and the purchase of cleaner vehicles
(planned implementation in 2021 until 2030)
Develop the connection of ships and boats at berth and infrastructure for maritime and inland
waterway transport (planned implementation to start in 2019)
Set up new low emission maritime zones (planned implementation to start in 2021)
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3.6.2 Pollutants targeted and projected emission reductions
Based on the justification set out in the previous section of this report, only nine of the PaMs reported
via the EEA PaM-tool were planned for implementation in 2019 or later at the time of the NAPCP
submissions. Estimated emission reductions were reported for only one of these – to reduce sulphur
content in domestic heating oil (where the planned implementation is due to start in the year 2028).
Estimated emission reductions of SO2 are reported for the years 2020 (10 kt), 2025 (8 kt) and 2030 (6
kt). It is unclear how the PaM is expected to deliver emission reductions before implementation, thus
the credibility of the PaM is very low.
3.6.3 Coherence between the PaMs considered and policy priorities
The related climate and energy policy priorities described in the NAPCP focus on achieving carbon
neutrality by 2050. The PaMs presented in the NAPCP with planned implementation start after 2019
are coherent with this policy priority in terms of clean energy measures for transport and domestic
heating.
PaMs targeting agriculture are also coherent with relevant policy priorities for the sector.
3.6.4 Responsible authorities and timescales for implementation of PaMs considered
Of the 10 PaMs where implementation is planned to start in 2019 or later, implementation is principally
the responsibility of national government ministries responsible for the sector targeted by the PaM.
Where the PaMs involve regulatory, fiscal and source-based policy instruments, the national
environmental authorities are responsible for policymaking and implementation. This can facilitate
consistency between regions and sectors.
For two of the PaMs targeting transport, regional authorities are involved with implementation. This
reflects the scale at which the PaMs are implemented (involving urban areas affected by air quality
issues arising from local road transport issues).
The planned implementation periods for the majority of the individual PaMs is reported to start in 2017
(and one even in 2015) and run indefinitely for the majority of the PaMs reported via the EEA PaM-tool.
As reported already, only 10 of the 50 PaMs adopted are planned for adoption in 2019 or later. As
reported above, planned implementation to reduce the sulphur content in domestic heating oil is
unrealistic – implementation is planned for 2028 but estimated emission reductions are reported for
2020, 2025 and 2030.
3.6.5 Details of the methodology for evaluation and selection of PaMs
The methodology for evaluation and selection of PaMs is provided in a separate document to the
NAPCP10. The report has not been reviewed as part of the NAPCP review.
3.6.6 Estimation of costs and benefits of the individual PaM or package of PaMs
considered
Cost and benefit data was not reported via the EEA PaM-tool but the cost analysis was conducted
during development of the national law adopting the PaMs (dated 10 May 2017). This analysis is
provided in a separate document to the NAPCP11. The report has not been reviewed as part of the
NAPCP review.
10 Annex 4: Methodology used to support the development of the national air pollution programme [Aide à la décision pour l’élaboration du
PREPA » Annexe D Méthodologie employee]. URL: https://www.ecologique-
solidaire.gouv.fr/sites/default/files/03_AnnexeD%20Méthodologie%20employée%20en%20ligne.pdf
11 Ibid.
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3.6.7 Impacts on air quality and the environment of individual PaMs or packages of
PaMs considered
Impacts on air quality are projected up to 2030 for PM10, PM2.5, NO2 and O3 (section 2.6.2 of the NAPCP)
but with very little detail. The maps provided show projected reductions in concentrations with marked
improvements in urban areas with large volumes of road transport. Despite projected improvements for
O3, exceedances with EU target values are still projected up to 2030.
The number of non-compliant air quality zones is projected to decrease for all four reported air quality
pollutants. By 2020, non-compliant zones are only projected for NO2 (with respect to the 40 µg/m3
average over a year) and O3 (with respect to the accumulated amount of O3 and 120 µg/m3 average
over a daily 8-hour period). The number of non-compliant zones is projected to decrease further
between 2020 and 2030 with 3 non-compliant zones projected for NO2 (from 10 in 2020) and 14 for O3
as an accumulated value (from 32 in 2020).
The policies selected for adoption by sector including
timetable for adoption, implementation and review and
responsible competent authority (M, O)
The NAPCP review finds that only 9 of the 50 individual PaMs selected for adoption are in fact
additional PaMs.
PaMs reported as selected for adoption target all relevant pollutants and sectors.
Coherence with air quality policy priorities is assessed in a separate report and the findings are
not reported in the NAPCP12.
3.7.1 Assessment of the credibility of the PaMs selected for adoption per sector
As reported in Section 3.6.1 of this review report, the PaMs reported by France were actually selected
and adopted by national legislation in 2017 (with varying implementation start years). Information
supporting the development of the national legislation is not reported in the NAPCP and has not been
reviewed as part of the NAPCP review as it is a separate document that was not submitted by France.
Estimated emission reductions were reported for 11 of the PaMs reported via the EEA-PaM tool. This
information is not presented here because all reported emission reductions were found to relate to
existing PaMs.
Of the nine PaMs used in the WAM scenario projections, estimated emission reductions were not
reported for the financial incentive to replace older polluting vehicles with clean energy ones. According
to the justification provided by France, the methodology to estimate the associated impact is not
reported because it was not developed at the time of the NAPCP submission. For the PaMs used in the
WAM scenario, implementation is reported to start from 2015 up to 2028. Implementation start dates in
the past are clearly inconsistent with the definition of additional measures thus the review finds that
these PaMs have been misreported and should have been included in the WM scenario instead. In
most cases, there was around 10 years for the PaMs to deliver the reported emission reductions, which
is considered realistic (albeit incorrectly reported as additional).
12 Plan national de réduction des émissions de polluants atmosphériques (PRÉPA), URL: https://www.ecologique-solidaire.gouv.fr/politiques-
publiques-reduire-pollution-lair#e4 [last accessed 26/11/2019].
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Agriculture
The required agricultural measures listed in Annex III, Part 2 to the NECD are part of existing measures
already adopted and being implemented by France according to national legislation adopted in 2017.
The PaMs are reported as not concerning small farms.
In the case of the optional measures listed, France has not established a national nitrogen budget or a
low protein feeding strategy to reduce NH3 emissions from manure. All other optional measures listed
in Annex III, Part 2 have been adopted as part of the 2017 national legislation.
Estimated emission reductions are not reported for any of the PaMs adopted and none of the PaMs are
used in the WAM scenario according to the information reported via the EEA PaM-tool. Thus, it is
unclear how France can achieve the projected emission reductions under the WAM scenario.
Implementation was planned to start in 2017 and while there has been the publication of a good practice
guide to improve air quality from agriculture13, no information is reported in the NAPCP regarding a
review process in place to monitor implementation.
Energy consumption
Estimated emission reductions are reported for two of the PaMs adopted, which are also used in the
WAM scenario according to the information reported via the EEA PaM-tool, as follows:
Reduce the sulphur content in heating oil (regulatory instrument; planned implementation in
2028)
Conduct testing for the performance of heating appliances on the market
The estimated emission reductions reported for the PaM to reduce the sulphur content in domestic fuel
is not credible because the planned implementation period (2028) is later than the projected emission
reductions (which are reported for 2020, 2025 and 2030).
Implementation of the measure consisting in testing the performance of heating appliances on the
market was planned to start in 2017. The description of the PaM does not provide sufficient detail to
justify the estimated emission reductions reported and so the credibility of the PaM is limited.
Transport
Implementation has started for the three PaMs targeting transport, as follows:
Converging taxation between gasoline and diesel (2018)
Real time emission controls (2015)
Establish restricted vehicle zones (2017)
The estimated emission reductions are feasible in the timescales reported (estimated to increase
incrementally from 2020 up to 2030).
Implementation of a financial incentive to replace older polluting vehicles with clean energy ones is
planned for 2021. The scale of the PaM is not described, and estimated emission reductions were not
reported and so the expected impact of the PaM cannot be determined. As such, the credibility of the
PaM is limited.
Cross-cutting
Of the cross-cutting PaMs adopted by national legislation in 2017, only one is used in the WAM scenario
according to the information reported via the EEA PaM-tool. The measure involves calls for research to
identify and evaluate technologies for reducing and controlling emissions of air pollutants and is
expected to deliver PM2.5 emission reductions from 2020 up to 2030. Examples of projects reported via
13 CITEPA (2019) Guide des bonnes pratiques agricoles pour l'amélioration de la qualité de l'air. https://www.ademe.fr/guide-bonnes-pratiques-
agricoles-lamelioration-qualite-lair
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the EEA PaM-tool are: evaluation study on the efficiency of technologies to reduce PM emissions linked
with braking and tyre abrasion; study on available alternatives to burning practices on agriculture land
(with respect to permanent crops such as vineyards); research into the impact of vegetation in cities;
and the development of tools to monitor real time emissions from road vehicles. It is unclear how the
reported emission reductions from that PaM were estimated given the PaM concerns only
commissioning of research projects.
Implementation was planned to start in 2017. The description of the PaM does not provide sufficient
detail to justify the estimated emission reductions reported and so the credibility of the PaM is limited.
3.7.2 Feedback from the consultation undertaken
There is no information provided on the consultation comments received, nor in general nor for the
individual or packages of PaMs selected for adoption,. Information in the NAPCP signposts to where
consultation responses were gathered at the time of the previously adopted programme (see Section
3.1 of the review)
3.7.3 Sources of funding
Information on the sources of funding is not reported.
3.7.4 Coherence with plans and programmes set up in other relevant policy areas
According to the information reported in the NAPCP, coherence between the selected PaMs and plans
and programmes for other relevant policy areas was assessed in 2015 to develop the air pollution
control plan adopted by national legislation in 2017. Multi-criteria analysis was conducted at the level
of individual PaMs based on the estimated emission reduction of each PaM, its potential contribution to
air quality improvements and the cost benefit ratio. This information is now very old and has not been
reviewed here as it is not included in the NAPCP and references have not been provided to identify the
external sources.
Projected combined impacts of PaMs on emission
reductions, air quality and the environment and associated
uncertainties (where applicable) (M, O)
Under the WAM scenario of the NAPCP (based on 2016 projections), the 2020-29 national
emission reduction commitments are projected to be achieved for all pollutants. The 2030
onwards commitments are projected to be achieved for NOx, NH3 and PM2.5 only.
The NAPCP review finds that a linear emission trajectory is not followed for NH3.
3.8.1 Likelihood of achievement of projected emission reductions
According to the projections included in the NAPCP, under the WAM scenario (based on 2016
projections), the 2020-29 national emission reduction commitments are projected to be achieved for all
pollutants. The 2030 onwards commitments are projected to be achieved for NOx, NH3 and PM2.5, and
missed for SO2 and NMVOCs. Conclusions from the NAPCP review on whether the projected emission
reductions per pollutant are likely to be realised in practice are presented in Table 3-1.
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Table 3-1 Likelihood of achieving the projected emissions reductions (WAM scenario)
Do the PaMs selected for adoption target
the key emitting sectors?
Are the projected emission reductions for
2020 and 2030 likely to be achieved?
SO2 Partly.
In 2017, combustion in industry was the
main source of SO2 emissions in France,
followed by combustion in other sectors.
The most significant contribution estimated
for the PaMs reported target emissions
from domestic heating.
No.
The planned implementation date of the
PaM expected to deliver the greatest SO2
emission reductions is after the period in
which estimated emission reductions are
reported. It is therefore unclear how the
PaM will deliver the estimated emission
reduction before it is implemented.
Furthermore, the detail of the PaM is not
clearly defined and so there is insufficient
information to determine its credibility.
NOX Yes.
In 2017, emissions from road transport
were the main source of NOx in France.
The most significant contribution estimated
for the PaMs reported target emissions
from road transport.
Partly.
Implementation was underway at the time
of the NAPCP submission (started in
2017). This allows for sufficient time to
achieve the estimated emission reductions
for 2020 onwards. Estimated emission
reductions are expected to increase
incrementally up to 2030. However, the
detail of the PaM is not clearly defined and
so there is insufficient information to
determine its credibility.
NMVOC No
NMVOC emissions in France came
predominantly from solvent and other
product use in 2017. However, the only
estimated emission reductions for NMVOC
come from PaMs targeting road transport.
Partly.
Implementation of relevant PaMs was
underway at the time of the NAPCP
submission (implementation started in
2017). This allows for sufficient time to
achieve the estimated emission reductions
for 2020 onwards. Estimated emission
reductions are expected to increase
incrementally up to 2030. However, the
detail of the PaMs is not clearly defined
and so there is insufficient information to
determine its credibility.
NH3 No.
Agriculture was the main source of NH3
emissions in France in 2017. The only
contribution estimated for the PaMs
reported target emissions from road
transport.
No.
The projected emission reductions under
the WAM scenario do not correspond to
the estimated emission reductions
reported for the PaMs. The detail of the
PaMs is not clearly defined and so there is
insufficient information to determine their
credibility.
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Do the PaMs selected for adoption target
the key emitting sectors?
Are the projected emission reductions for
2020 and 2030 likely to be achieved?
PM2.5 Yes.
Combustion in other sectors was the main
source of PM2.5 emissions in France in
2017. The most significant contribution
estimated for the PaMs reported target
emissions from domestic heating (calls for
research to identify and evaluate
technologies for reducing and controlling
emissions of air pollutants).
Partly.
Implementation was underway at the time
of the NAPCP submission (started in 2017).
This allows for sufficient time to achieve the
estimated emission reductions for 2020
onwards. Estimated emission reductions
are expected to increase incrementally up
to 2030. It is unclear how the reported
emission reductions from that PaM were
estimated given the PaM concerns only
commissioning of research projects.
This analysis of the credibility of the PaMs in achieving emission reductions has also been used in the
assessment of the risk of non-compliance, presented in Appendix 2.
3.8.2 Deviation from the linear trajectory for 2025
It is reported that linear emission reduction trajectories are followed for all NECD pollutants.
The NAPCP review finds that a linear emission trajectory is not followed for NH3. However, the extent
to which the linear emission trajectory is not observed is minor (a degree of 1 percentage point) and the
NH3 2020-29 and 2030 commitments are projected to be achieved. Furthermore, it is not possible to
establish which of the emission reduction values reported (as kt or as a percentage of the 2005 baseline
year) is the correct projection data (Section 2.2). The deviation from the linear trajectory is specific to
the projected emission trajectory when using the emission reductions calculated as a percentage of the
2005 baseline year. Therefore, the NAPCP review finds that the description reported by France in the
NAPCP is adequate on this matter.
3.8.3 Use of flexibilities
No information with regard to flexibilities is reported. Therefore, it is assumed that flexibilities are not
applicable.
3.8.4 Projected impacts on air quality and the environment.
The projected impacts on air quality and the environment are not reported for PaMs selected for
adoption.
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4 Conclusions and recommendations
Conclusions
France did not meet the reporting deadline, submitting its NAPCP after the 1 April 2019. The common
format established by the Commission Implementing Decision (2018/1522) has been used and so has
the EEA-PaM tool.
The minimum content is provided for many aspects of the NAPCP. However, reporting gaps are evident
which affect the quality of the NAPCP, as follows:
Progress made by current PaMs in reducing NMVOC was not reported.
The current transboundary impact of national emission sources was not reported.
Under the WM scenario, the projected impact on improving air quality is not reported.
Although projections are presented in the NAPCP, the information reported is outdated as it is based
on 2013 and 2016 projections and a report adopted by France in 2017. Furthermore, the differences
identified between the emission reduction values reported as kt compared to the values calculated as
a percentage of the 2005 baseline year bring in to question the quality of the projections data presented
in the NAPCP.
The NAPCP review finds that the PaMs reported are not additional. They already exist and form part of
national legislation adopted in 2017. Therefore, the NAPCP review finds that these PaMs should be
included in the WM scenario rather than being presented as additional PaMs for inclusion in the WAM
scenario. The fact that the PaMs relate to existing PaMs rather than additional ones means that the
projected emission reductions associated with them would have resulted in lower emissions under the
WM scenario, and less reduction under the WAM scenario. However, the overall compliance gap from
the commitments would be the same as projected under the WAM scenario.
According to the NAPCP projections under the WAM scenario, France is not expected to meet its
national emission reduction commitment for SO2 and NMVOC for 2030 onwards. The PaM targeting
emission reductions of SO2 (as reported by France via the EEA PaM-tool), is judged in the review as
having low credibility because the planned implementation is after the period in which estimated
emission reductions are reported. For NMVOC, the only emission reductions from the PaMs reported
will be achieved in the road transport sector and are minor. The NAPCP review concludes that additional
PaMs are needed and could be better targeted to the key emitting sources for these pollutants (i.e.
combustion in industry and solvent use).
According to the NAPCP projections reported under the WAM scenario, compliance with the 2030
commitments for NOx, NH3 and PM2.5 is projected to be achieved by 3, 0 and 5 percentage points,
respectively. The differences between the NAPCP projections and the projections submitted under
Article 10(2) do not affect the conclusions on compliance for these pollutants (Section 2.2 of this report).
The estimated emission reductions are dependent on the implementation of PaMs which were adopted
by national legislation in 2017. The NAPCP review finds that the detail of the PaMs is not clearly defined
and so there is insufficient information to determine the credibility of the PaMs.
These findings are flagged in the risk assessment presented in Appendix 2 to this report; however, no
conclusions have been drawn on the risk of non-compliance as the late submission of the Article 10(2)
projections meant that the quality could not be reviewed as part of the projections review that was
conducted ahead of the French NAPCP review.
A positive counterpart to the fact that France has reported already existing PaMs instead of the required
additional ones is that the NAPCP provides a detailed description of current PaMs together with
implemented EU legislation that provides a good basis for understanding progress achieved to date.
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Recommendations
Recommendations are prioritised according to the following categories:
1. Ensuring compliance – non-compliance with the NECD, where the minimum content is not
reported and/or the Member State does not demonstrate how it may achieve its emission reduction
commitments.
2. Areas for improvement – the NAPCP is reported to be compliant with its emission reduction
commitments and provides the minimum content required by the common format but areas for
improvement to strengthen compliance have been identified.
3. Encouragements – where optional reporting and/or the NAPCP could be closer aligned with the
guidance document on preparation of initial NAPCPs to strengthen the quality of the NAPCP.
Ensuring compliance
According to the NAPCP projections under the WAM scenario, SO2 and NMVOC 2030 onwards
commitments are projected to be missed. To ensure compliance, France should consider and adopt
further additional PaMs. The NAPCP review finds that further additional PaMs could target SO2
emissions from combustion in industry and NMVOC emissions from solvent use.
Progress achieved by current PaMs for NMVOC is not reported in the corresponding section of the
NAPCP. France is required to report on progress achieved by current PaMs and the degree of
compliance with national and Union emission reduction legislation for all NECD pollutants.
Where relevant, Member States are required to describe the current transboundary impact of
domestic emission sources. France has reported that this has not been estimated. This response
is insufficient and these impacts need to be reported.
Member States are required to report the policy options considered in order to comply with the
emission reduction commitments for 2020-29, and 2030 onwards. These shall be additional to
existing PaMs, i.e. they shall not include implementation of existing EU legislation and they shall
not include PaMs where national implementation was already underway at the time of the NAPCP
submission. All PaMs reported via the EEA-PaM tool by France were adopted by national legislation
in 2017 with implementation starting in the year 2015 in some cases and therefore are not
additional. To ensure compliance, France is required to present information for additional PaMs, at
least for SO2 and NMVOC.
Areas for improvement
The NAPCP projections under a WM scenario were developed in 2013. Existing PaMs adopted
between 2013 and 2017 are therefore not captured by the inventory data used to underpin the
projections. This adds to the uncertainty of the projections. The NAPCP projections under the WAM
scenario were developed in 2016. None of the NAPCP scenarios is consistent with projections
reported in 2019 under Article 10. Consistency should be sought between all scenarios based on
latest data.
Under the WAM scenario, the respective emission reduction commitments for NOx (for 2030
onwards), NH3 (for 2020-29 and 2030 onwards), and PM2.5 (for 2030 onwards) are projected to be
achieved by 3, 0 and 5 percentage points, respectively. To strengthen the certainty with which
France can meet the respective commitments according to the emission reductions projected in the
NAPCP, France should consider and adopt additional PaMs.
The climate and energy policy priorities reported and the coherence assessment with relevant
priorities do not cover the National Energy and Climate Plan (NECP). It is recommended that France
reports on how coherence with the NECP has been achieved.
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Encouragement
Air quality policy priorities and impacts are not described in any detail, nor are the costs of the
measures. France is encouraged to present more information in the NAPCP on this.
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Appendix 1 Completeness assessment
A completeness assessment was conducted to identify gaps in reporting according the minimum
content requirements of the common format (Commission Implementing Decision (EU) 2018/1522).
The completeness assessment also reviewed the extent of optional reporting by Member States.
For mandatory reporting requirements, the status has been assessed using the traffic light RAG rating
as presented in the table below.
Table A1 - 1 Traffic light RAG rating for completeness assessment of mandatory reporting
Red No information provided for mandatory reporting requirement
Amber Evidence is incomplete or unclear to meet reporting requirement
Green Evidence is sufficient to meet reporting requirement
N/A Mandatory reporting requirement not relevant for the given Member State or
mandatory only when available and not available in the given Member State (e.g.
where mandatory reporting requirements apply only where a non-linear emission
reduction trajectory is followed)
Table A1 - 2 Assessment of the NAPCP compliance screening with the minimum content requirements
Reference to the NAPCP common
format
RAG
Rating
Explanation
2.1 Title of the programme contact
information and websites
Green The NAPCP is appropriately introduced.
2.3.1 Policy priorities and their
relationship to priorities set in other
relevant policy areas
Green France reported policy priorities for emission
reductions and other relevant policies
already in place, as regards air quality,
climate change and energy, transport and
agriculture.
2.3.2 Responsibilities attributed to
national, regional and local authorities
Green The NAPCP meets all reporting
requirements relating to the responsibilities
attributed to national, regional and local
authorities.
2.4.1 Progress made by current PaMs in
reducing emissions, and the degree of
compliance with national and Union
emission reduction obligations
Red Progress made by current PaMs in reducing
NMVOC was not reported and it is unclear
what are current and new PaMs (since what
is reported as new PaMs are actually part of
the existing ones).
2.4.2 Progress made by current PaMs in
improving air quality, and the degree of
compliance with national and Union air
quality obligations
Green France reported progress achieved by
current PaMs in improving air quality for
select air pollutants and described
compliance.
2.4.3 Where relevant, current
transboundary impact of national emission
sources
Red The current transboundary impact of national
emission sources was not reported.
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Reference to the NAPCP common
format
RAG
Rating
Explanation
2.5.1 Projected emissions and emission
reductions (WM scenario)
Amber France reported projections under a WM
scenario based on 2013 projections,
showing emission reductions compared with
a 2005 base year for all NECD pollutants
against the Member State commitments (as
stipulated by the NECD). The year of the
inventory data used to underpin the
projections was not reported but is
necessarily older than 2013.
2.5.2 Projected impact on improving air
quality (WM scenario)
Red The projected impact on improving air quality
is not reported
2.6.1 Details concerning the PaMs
considered in order to comply with the
emission reduction commitments
(reporting at PaM level)
Amber France provides the minimum content for
this reporting requirement using the EEA
PaM-tool. However, the PaMs reported are
not additional according to the NAPCP
review.
2.6.2 Impacts on air quality and the
environment of individual PaMs or
packages of PaMs considered in order to
comply with the emission reduction
commitments (where available)
Amber France reported the minimum content for
this reporting requirement in the NAPCP.
However, the PaMs reported are not
additional according to the NAPCP review.
2.6.4 Additional details concerning the
measures from Annex III Part 2 to
Directive (EU) 2016/2284 targeting the
agricultural sector to comply with the
emission reduction commitments
Amber France provides the minimum content for
this reporting requirement using the EEA
PaM-tool. However, the PaMs reported are
not additional according to the NAPCP
review.
2.7.1 Individual PaMs or package of PaMs
selected for adoption and the competent
authorities responsible
Amber France provides the minimum content for
this reporting requirement using the EEA
PaM-tool. However, the PaMs reported are
not additional according to the NAPCP
review.
2.7.2 Assessment of how selected PaMs
ensure coherence with plans and
programmes set up in other relevant
policy areas
Amber France reported the minimum content for
this reporting requirement in the NAPCP.
However, the PaMs reported are not
additional according to the NAPCP review.
2.8.1 Projected attainment of emission
reduction commitments (WAM)
Amber France reported projections under a WAM
scenario based on 2016 projections,
showing emission reductions compared with
a 2005 base year for all NECD pollutants
against the national commitments (as
stipulated by the NECD). The year of the
inventory data used to underpin the
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Reference to the NAPCP common
format
RAG
Rating
Explanation
projections was not reported but is
necessarily older than 2016.
2.8.2 Non-linear emission reduction
trajectory
Amber The NAPCP review finds that a linear
emission trajectory is not followed for NH3 (by
a degree of 1 percentage point). However,
the NH3 2020-29 and 2030 commitments are
projected to be achieved. Therefore, the
NAPCP review finds that the lack of
description reported by France in the NAPCP
is not a significant reporting gap.
2.8.3 Flexibilities n/a Flexibilities are not used.
The rating used for the completeness assessment of optional reporting by Member States refers to only
two categories, whereby the Member State either reported the information (Green) or it did not (White).
This rating reflects the fact that the reporting is optional and therefore where the information was not
provided, or where it was incomplete or unclear, the assessment should not consider this a gap in
reporting.
Table A1 - 3 Rating for completeness assessment rating of optional reporting
Green Evidence is sufficient to meet reporting requirement
White No information provided for optional reporting requirement or evidence is
incomplete or unclear to meet optional reporting requirement
Table A1 - 4 Completeness assessment of the NAPCP for the optional content requirements
Reference to the NAPCP common
format
RAG
Rating
Explanation
2.2 Executive summary White Only an external weblink is provided to an
executive summary that relates to an older
document.
2.3.1 Policy priorities and their
relationship to priorities set in other
relevant policy areas: Reference to WHO
guideline values
White France has not reported any information on
this aspect.
2.3.2 Responsibilities attributed to
national, regional and local authorities:
Source sectors under the responsibility of
the authority
White France has not reported any information on
this aspect.
2.4.1 Progress made by current PaMs in
reducing emissions, and the degree of
compliance with national and Union
Green A line chart illustrating the emission
reductions per pollutant is provided.
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Reference to the NAPCP common
format
RAG
Rating
Explanation
emission reduction obligations: Provision
of graphics
2.4.2 Progress made by current PaMs in
improving air quality, and the degree of
compliance with national and Union air
quality obligations: Provision of graphics
and progress made in a specific air quality
zone
Green An indexed line chart showing the evolution
of air quality pollutant concentrations is
provided.
2.4.3 Methodologies and data used to
show the current transboundary impact of
national emission sources
White France has not reported any information on
this aspect.
2.5.1 Associated uncertainties of the
projected emissions and emission
reductions (WM scenario)
Green Associated uncertainties for the WM
projections to meet the emission reduction
commitments for 2020, 2025 and 2030
onwards is reported.
2.5.2 Quantitative data on the projected
impact on improving air quality (WM
scenario)
White France has not reported any information on
this aspect.
2.6.1 Details about additional pollutants
concerning the PaMs considered in order
to comply with the emission reduction
commitments: Reporting of affected
pollutant(s) beyond the scope of the
NECD
White France has not reported any information on
this aspect.
2.6.3 Estimation of costs and benefits of
the individual PaM or package of PaMs
considered in order to comply with the
emission reduction commitments
White An external weblink is provided to an annex
for the older document.
2.6.4 Additional details concerning the
optional measures from Annex III Part 2 to
Directive (EU) 2016/2284 targeting the
agricultural sector to comply with the
emission reduction commitments
Green Information on optional agricultural
measures is reported in the NAPCP.
2.7.1 Individual PaMs or package of PaMs
selected for adoption and the competent
authorities responsible: Reporting of
relevant comments arising from the
consultation and provision of interim
targets and indicators
White France has not reported any information on
this aspect.
2.7.2 Explanation of the choice of
selected measures
White France has not reported any information on
this aspect.
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Reference to the NAPCP common
format
RAG
Rating
Explanation
2.8.4 Projected improvement in air quality
(WAM)
White France has not reported any information on
this aspect.
2.8.5 Projected impacts on the
environment (WAM)
White France has not reported any information on
this aspect.
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Appendix 2 Assessment of the risk of non-compliance The description of the methodology used for this assessment is presented in the Horizontal Report.
In the following tables, the information used in the decision tree process is presented in black font.
Information not used in the decision tree process is presented in grey font and italics.
Where information is required but not reported, the response to the decision tree question is ‘not
reported’ (NR). Where information is not required and not reported, the response to the decision tree
question is ‘not applicable’ (n/a).
Risk of non-compliance with 2020-2029 emission reduction commitments
Decision tree question Relevant
scenario
2020 – 2029
SO2 NOx NMVOC NH3 PM2.5
Can the Member State
achieve the emission
reduction commitments?
(projections submitted
under Article 10(2))
WM Yes No Yes No Yes
WAM Yes Yes Yes Yes Yes
Are the projections
submitted under Article
10(2) considered to be of
good quality?
WM,
WAM
Are the NAPCP projections
consistent with the latest
projections submitted under
Article 10(2)?
WM No No No No No
WAM No No No No No
Does the NAPCP present
credible additional PaMs
selected for adoption?
WAM No Partially Partially No Partially
Is the margin of compliance
(percent of the compliance
threshold) likely to ensure
compliance with the
emission reduction
commitments? (projections
submitted under Article
10(2))
WM Yes
(47)
No (-3) Yes
(13)
No (-3) Yes
(22)
WAM Yes
(53)
Yes (6) Yes
(12)
No (0) Yes
(22)
Risk of non-compliance
Additional comments on
high risk scores
The late submission of projections under Article 10(2) meant that
the quality of projections was not reviewed as part of the
projections review which was carried out in 2019. The risk
assessment thus could not be completed.
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Risk of non-compliance with 2030 emission reduction commitments
Decision tree question Relevant
scenario
2030 onwards
SO2 NOx NMVOC NH3 PM2.5
Can the Member State
achieve the emission
reduction commitments?
(projections submitted
under Article 10(2))
WM Yes No Yes No Yes
WAM Yes Yes Yes Yes Yes
Are the projections
submitted under Article
10(2) considered to be of
good quality?
WM,
WAM
Are the NAPCP projections
consistent with the latest
projections submitted under
Article 10(2)?
WM No No No No No
WAM No No No No No
Does the NAPCP present
credible additional PaMs
selected for adoption?
WAM No Partially Partially No Partially
Is the margin of compliance
(percent of the compliance
threshold) likely to ensure
compliance with the
emission reduction
commitments? (projections
submitted under Article
10(2))
WM No (4) No (-10) Yes (6) No (-7) Yes (2)
WAM Yes
(31)
Yes
(16)
Yes (8) No (3) No (0)
Risk of non-compliance
Additional comments on
high risk scores
The late submission of projections under Article 10(2) meant that
the quality of projections was not reviewed as part of the
projections review which was carried out in 2019. The risk
assessment thus could not be completed.
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