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Review of the National Air Pollution Control Programme – Slovenia
___________________________________________________ Final Report for European Commission – DG Environment Specific contract 070201/2018/791186/SER/ENV.C.3
ED 11495 | Issue Number 5 | Date 01/10/2020
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Author:
Andrea Illes, Hetty Menadue
Approved By:
Natalia Anderson
Date:
01 October 2020
Ricardo Energy & Environment reference:
Ref: ED11495 - Issue Number 5
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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) .................. 18
Policy options considered to comply with emission reduction commitments for 2020 and
2030, intermediate emission levels for 2025 and stakeholder consultation (M, O) .................... 19
The policies selected for adoption by sector including timetable for adoption,
implementation and review and responsible competent authority (M, O) .................................. 21
Projected combined impacts of PaMs on emission reductions, air quality and the
environment and associated uncertainties (where applicable) (M, O) ....................................... 23
4 Conclusions and recommendations ....................................................................... 26
Conclusions ..................................................................................................................... 26
Recommendations .......................................................................................................... 27
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
Eionet The European Environment Information and Observation Network
EU European Union
GHG Greenhouse Gas
kt Kilo tonne
NAPCP National Air Pollution Control Programme
NECD National Emissions Ceiling Directive
NECP National Energy and Climate Plans
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) for Slovenia. A draft NAPCP was provided by the European Commission on 20 June 2019 for the purpose of the review. A final NAPCP was submitted on 10 October 2019 and the review was amended to reflect this final submission.
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 risk 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 NAPCP and robustness of the data provided.
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.
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 Member States are reliant on additional PaMs (as included in the ‘With
Additional Measures’ (WAM) scenario) to achieve compliance.
The extent to which the evidence provided on selected PaMs is robust and the level of confidence
it provides that 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 Directive
objectives and; 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 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 draft NAPCP was provided by the European Commission for the purpose of the review on 20 June 2019. The final NAPCP was uploaded to the European Environment Information and Observation Network (Eionet)4 on 10 October 2019.
Was the common format used? Partially Slovenia does not use the common format but the headings for the respective sections are the same.
What is the length of the NAPCP? 70 pages
What language is the NAPCP reported in? Slovenian An official translation is published by the European Commission5.
What language is the supporting documentation reported in?
Not applicable Supporting documentation was not submitted.
How many external documents are referenced or provided in the NAPCP?
Six Weblinks were provided for six external data sources.
Is it possible to identify the required information in the external documents (i.e. is the page and chapter reference provided)?
No
Slovenia does not include page or chapter numbers in the references provided and web pages are not specified for the weblinks provided.
Can all external documents be accessed? Yes The weblinks provided are to publicly available websites.
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
States. The results show a few gaps in Member State reporting mainly related to information presented
for additional PaMs, as presented in Appendix 1 to this review. To summarise, the NAPCP for Slovenia
includes the minimum content required for:
Policy priorities for emission reductions and other relevant policy priorities and the responsible
authorities involved.
Progress made by current PaMs in reducing emissions and improving air quality, and the current
transboundary impact of national emission sources.
4 Eionet: Reporting obligation for: National Emission Ceiling Directive (NECD) - National air pollution control programmes. URL:
https://rod.eionet.europa.eu/obligations/753 [last accessed 20 December 2019].
5 https://ec.europa.eu/environment/air/reduction/NAPCP.htm
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NAPCP projections of emissions and emission reductions with existing measures and their
projected impact on improving air quality.
Limited information is presented on the additional PaMs considered to comply with the emission
reduction commitments.
Information on the adopted measures listed in Annex III Part 2 to Directive (EU) 2016/2284 targeting the agricultural sector to comply with the emission reduction commitments.
Limited information is presented for the additional PaMs selected for adoption. Relevant air quality, energy and transport policies and programmes are presented for these PaMs.
NAPCP projections to show projected attainment of emission reduction commitments (WAM) and
an overview of the flexibilities used.
Gaps in the reporting of minimum content are:
Detail for the relevant policy priorities in industry is missing.
The year of the NAPCP projections is not presented for the NAPCP projections (for both the WM
and WAM scenarios).
Estimated emission reductions are not reported and no information is provided to show the
expected impacts on air quality and the environment of the PaMs considered.
Limited information is presented for the additional PaMs selected for adoption. No assessment of how selected PaMs ensure coherence with air quality objectives or with other relevant plans and programmes is presented in the NAPCP.
Optional content is provided as follows:
An executive summary.
Competent authorities responsible for source sectors.
The use of graphics to portray current progress achieved and projected impact on air quality
improvements.
An account of the uncertainties associated with the NAPCP projections under the WM scenario.
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.
A qualitative description of the expected impact (under the WAM scenario) on PM2.5, PM10 and NO2
concentrations by 2030.
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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)
The NAPCP projections with existing measures (WM scenario) show that Slovenia is projected
to achieve its 2020-2029 national commitments for all five NECD pollutants. Under the WM
scenario, for 2030 onwards, NMVOC and PM2.5 commitments are projected to be missed. SO2,
NOX and NH3 commitments are projected to be achieved.
According to the NAPCP projections with additional measures (WAM), Slovenia is projected to
achieve greater emission reductions for all NECD pollutants except SO2 for which, emission
levels are projected to remain the same compared to the WM scenario. Despite the greater
emission reductions, the projected emission reductions under WAM scenario are insufficient for
Slovenia to meet the 2030 onwards NMVOC and PM2.5 commitments.
The projections presented in this section are derived from the information reported by the Member State
in their NAPCP. The projections in the NAPCP are different to the projections submitted separately by
Slovenia under Article 10(2) of the Directive on 13 March 2019. Both use 2017 inventory data to
underpin the projections (as the latest historic year). The differences between the two sets of projections
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do not materially affect the projected compliance with the emission reduction commitments except in
the case of SO2 and NOx, as described at the end of this section.
Table 5 of the NAPCP “Projections with measures by 2030 and emission reductions compared to 2030
targets” reports total emissions (in kt) for 2005, as well as 2017, 2020, 2025 and 2030. It also presents
reductions in emissions that are projected in the future years, expressed as a percentage of 2005
emissions. All figures in the table are rounded either to zero or one decimal point. When 2020 emission
reductions for NOx expressed as a percentage of 2005 reductions are rounded and then compared to
the respective 2020-29 emission reduction commitment, the analysis suggests that the commitment is
achieved. Indeed section 4.1.2 of the NAPCP states “Total projected NOx emissions in 2020 are 32.4
kt and 18.1 kt in 2030. Compared to 2005, this represents a decrease of 39 % and 66 % respectively,
and these are exactly the reductions required to achieve the objectives”. However, if the reductions are
not rounded, the analysis shows that the commitment is actually projected to be missed with a margin
of 0.48 percentage points. To validate these findings, the review team has also assessed Slovenia’s
projected compliance according to Article 10(2) projections. According to the Article 10(2) projections,
Slovenia projects to miss the 2020-29 commitment for NOx. It is clear therefore that the conclusions
drawn in the NAPCP on the Slovenia’s projected compliance with NOx 2020-29 emission reductions
commitment are incorrect. The same discrepancy has been noted for SO2 2030 onwards emission
reduction commitment. The rounding of emission reductions suggests that the commitment will be
achieved exactly, with no margin. Without the rounding, the commitment would be missed by 0.42
percentage points. As the projected emissions for SO2 are the same under WM and WAM scenarios
presented in the NAPCP, the same discrepancy is also noted for this pollutant in the WAM scenario for
2030.
In addition, the review has found that emission reductions for PM2.5 presented in Table 5 of the NAPCP
are incorrect. Instead of 31% reduction in 2020, it should be 28% and instead of 52% in 2020, it should
be 50%. This error is corrected in section 4.1.4 of the NAPCP which describes historical and future
trends in emissions of PM2.5. These differences however do not affect conclusions on compliance with
PM2.5 emission reduction commitments.
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 Slovenia 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
25 percentage points.
NOX – The projections of NOX emissions under the WM scenario show that Slovenia 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
0.48 percentage points. However, the NAPCP states that the commitment will be achieved exactly,
with no margin.
NMVOC – The projections of NMVOC emissions under the WM scenario show that Slovenia 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 19 percentage points.
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NH3 – The projections of NH3 emissions under the WM scenario show that Slovenia 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
7 percentage points.
PM2.5 – The projections of PM2.5 emissions under the WM scenario show that Slovenia 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.
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 Slovenia 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 0.42 percentage points. However, the NAPCP states that the commitment will be
achieved exactly, with no margin.
NOX – The projections of NOX emissions under the WM scenario show that Slovenia 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 with a
margin of 1 percentage point.
NMVOC – The projections of NMVOC emissions under the WM scenario show that Slovenia cannot
comply with the 2030 onwards reduction commitments specified in the NECD with existing
measures. However, compliance with the emissions reduction commitments is projected to be
missed with a margin of 8 percentage points.
NH3 – The projections of NH3 emissions under the WM scenario show that Slovenia 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 with a
margin of 1 percentage point.
PM2.5 – The projections of PM2.5 emissions under the WM scenario show that Slovenia 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 8 percentage point.
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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 the commitment is projected to be missed.
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 Slovenia 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
25 percentage points.
NOX – The projections of NOX emissions under the WAM scenario show that Slovenia 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
2 percentage points.
NMVOC – The projections of NMVOC emissions under the WAM scenario show that Slovenia 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 20 percentage points.
NH3– The projections of NH3 emissions under the WAM scenario show that Slovenia 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
8 percentage points.
PM2.5– The projections of PM2.5 emissions under the WAM scenario show that Slovenia 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
7 percentage points.
Under the WAM scenario, progress towards the 2030 onwards commitments is as follows:
SO2 – The projections of SO2 emissions under the WM scenario show that Slovenia 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 0.42 percentage point. However, the NAPCP states that the commitment will be achieved
exactly, with no margin.
NOX – The projections of NOX emissions under the WM scenario show that Slovenia 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 2 percentage points.
NMVOC – The projections of NMVOC emissions under the WM scenario show that Slovenia 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 4 percentage points.
NH3– The projections of NH3 emissions under the WM scenario show that Slovenia 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 1% point.
PM2.5– The projections of PM2.5 emissions under the WM scenario show that Slovenia 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 3 percentage points.
Figure 2-3 Projected attainment of emission reduction commitments (WAM scenario used in the NAPCP)
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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 the commitment is projected to be missed.
Differences between the projections in the NAPCP and those submitted separately under Article 10(2)
on 13 March 2019 are as follows:
The emission projections differ for all NECD pollutants between the NAPCP projections and those submitted under Article 10(2). However the differences only affect projected compliance for the NOx 2020-29 commitment and the SO2 2030 onwards commitment. In both cases, the differences occur because the projected emission reductions as a percentage of the 2005 baseline year are rounded up in the NAPCP projections but reported to two decimal points for the projections submitted under Article 10(2). This allows the projected percentage emission reductions to meet the percentage emission reduction commitments exactly according to the information presented in the NAPCP, while missing the respective commitments according to the projections submitted under Article 10(2).
The NAPCP projections include a WAM scenario which has not been submitted under Article 10(2).
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 10 October 2019, after the deadline of 1 April.
The common format was not used by Slovenia.
No information is provided on the consultation activities undertaken for the development of the
NAPCP.
The NAPCP does not adhere to the common format specified by the Commission Implementing
Decision (EU) 2018/1522, pursuant to Article 6 of the NECD. The NAPCP is made up of one main report
(66 pages) and is not accompanied by supporting documentation. Of the six external links provided, all
are in working order. External references are publicly available.
The final NAPCP was submitted on 10 October 2019, building on an earlier draft which was submitted
to the European Commission on 20 June 2019. The delay was indicated to be due to the need to
harmonise the programme with the National Energy and Climate Plan (NECP). PaMs were submitted
via the EEA PaM-tool on 25 November 2019.
Slovenia clearly indicates the title of the document and identifies the competent authority responsible
for it as the Ministry of Environment and Spatial Planning.
No website link is provided to access information on the consultation activities undertaken for the
NAPCP. It is unclear if any consultation activities have been undertaken. The transboundary impact of
air pollution is outlined in the NAPCP (section 3.3 of the NAPCP); however, there is no evidence of a
transboundary consultation being conducted.
Executive summary (O)
A two-page executive summary is provided (section 1 of the NAPCP). It does not follow the structure
of the common format but covers most of the suggested content (only a summary of the coherence
assessment is missing). In sum, the executive summary provided by Slovenia is structured as follows:
The emission commitments under the NECD.
The main sources of emissions.
The national policy framework (including the responsible authority).
Progress made with existing measures and identification for areas of non-compliance.
Planned additional measures.
Projections with additional measures.
The information in the executive summary is consistent with the content of the NAPCP.
The national air quality and pollution policy framework (M, O)
Air quality policy priorities are presented for PM10.
The relevant climate change and energy policy priorities are described in the context of the
NECP, the National Renewables Action Plan and the Energy Efficiency Action Plan (section 2.1
of the NAPCP).
Agriculture, transport and development policy priorities are described in section 2.1.4.
An overview of all responsible authorities is provided in section 2.2.
Slovenia’s national air quality and pollution policy framework is presented in section 2 of the NAPCP,
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Relevant policy priorities are described in Section 2.1. In sum:
Air quality policy priorities are presented for PM10 (section 2.1.2 of the NAPCP), referring to an air
quality plan for PM10 and an operational programme for the reduction of PM10 emissions. Slovenia
does not refer to the WHO guideline values for the air quality priorities described.
The EEA air quality country fact sheet6 indicates that there have been exceedances of the EU limit
and target values for PM10 and O3 in Slovenia. Beyond stating the corresponding EU legal
requirements, O3 is not described among the air quality priorities presented in the NAPCP.
The current policy priorities for climate change and energy are described in the context of the NECP,
which does not include the non-ETS GHG reduction target (section 2.1.3).
For renewable energy, the policy priorities are described in the context of the National Renewables
Action Plan (2010-2020), including the objective to achieve a 25% share of RES of final gross
energy consumption by 2020 (section 2.1.3).
Energy efficiency policy priorities are established by the national Energy Efficiency Action Plan
(2017-2020) and a Long-term Strategy for Promoting Energy Renovation in Buildings (section
2.1.3).
Relevant agriculture and transport policy priorities are set out in a National Development Strategy
2030 (section 2.1.4). Industry policy priorities are not covered.
In section 2.2 of the NAPCP, the responsible authorities are described in an overview table. The Ministry
of Environment and Spatial Planning has the primary responsibility for drafting legislation and
programmes on air pollution and air quality and has a coordinating role. In addition, regional and local
authorities also have a policy making role. Optional reporting concerning the responsible authorities for
specific source sectors is included in the table with reference to policy making (including the Ministry of
Infrastructure, the Ministry of Economic Development and Technology and the Ministry of Agriculture,
Food and Forestry). The Ministry of Health is also listed but it does not have a policy making role. The
NAPCP review finds that the role of the national government overseeing air pollution matters will
facilitate coordination between sectors and regions in implementation of the NAPCP. It also finds that
local involvement can strengthen implementation through more targeted action at a local level.
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
Progress made by current PaMs and EU policies in reducing emissions is described by pollutant.
The detail of the PaM description and their impacts, in terms of emission reductions, are not
presented consistently across all PaMs.
Drivers behind the emission reductions to date are described for: agriculture (NH3); energy
supply, industry and transport sectors (SO2, NOX and NMVOC); buildings (SO2 and NMVOC);
waste management and solvent use (NMVOC); and the energy consumption and transport
sectors (PM2.5).
Progress made in reducing emissions is described to varying degrees by pollutant (section 3.1 of the
NAPCP). Where provided, progress achieved by current PaMs is summarised by emission source
together with the timeframe in which progress has been achieved.
6 Air pollution country fact sheets 2018: https://www.eea.europa.eu/themes/air/country-fact-sheets [last accessed: 16/07/2019]
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Drivers behind the emission reductions to date, including current PaMs and EU policies, have been
described with reference to their titles, relevant sectors (agriculture, buildings, households, industrial
processes, energy, transport and waste management) and affected pollutants.
PaMs and EU policies delivering SO2 emission reductions are described as:
2015 measures related to the Trbovlje and Šoštanj thermal power plants (Energy supply);
Application of the IPPC Directive introducing the requirement for installations to apply the Best
Available Techniques (BAT) and to introduce an environmental permit in 2007 (Industry);
Reduction of the sulphur content of liquid fuels (diesel, petrol, heating oil) in 2008 (Transport);
Measures to improve energy efficiency in all sectors, most notably in buildings; and
Measures to promote renewable energy sources.
PaMs and EU policies delivering NOX emission reductions are described as:
Implementation of primary measures on thermal power plants in the process of adapting to
emission limits for large energy installations and restructuring of the sector (Energy supply);
Tightening of Euro standards for new vehicles (Transport).
PaMs and EU policies delivering NMVOCs emission reductions are described as:
Decree on limit values for emissions of volatile organic compounds into the air from installations
using organic solvents (Industry);
Tightening of Euro standards for new vehicles (Transport);
Implementation of regulations on volatile organic compounds to air from petrol storage and transfer
petrol;
Reduction in the level of disposed waste (Waste);
Industrial restructuring and improving energy efficiency (Industry);
Improving energy efficiency in buildings.
PaMs and EU policies delivering NH3 emission reductions are described as:
Implementation of measures to reduce nitrogen losses in agriculture (Agriculture) - a list of
measures with reference to Annex III, Part 2 of the NECD is provided (detail is provided in section
3.7.1 of this review report).
PaMs and EU policies delivering PM2.5 emission reductions are described as:
2. Decrease in the share of households using wood biomass in old boilers: encouraging the
replacement of old boilers for wood with modern boilers, heat pumps, gas condensing boilers,
encouraging connection to district heating systems (Energy consumption);
3. Tightening of Euro standards for new vehicles (Transport).
Adding to this, existing PaMs and EU legislation that also contribute to reductions of GHG emissions
are presented in Annex 1 to the NAPCP. A total of 25 PaMs are described which were implemented
mainly between 2001 and 2011.
The impacts of the PaMs expressed in terms of the emission reduction achievements is not described
consistently. General emission trends are described for each of the pollutants in section 3.1 of the
NAPCP. Graphics are provided to illustrate emission reductions per pollutant and per sector (see
Figures 1 – 12 of the NAPCP).
3.4.2 Progress made by current PaMs in improving air quality
Table 2 in the NAPCP shows concentrations of NO2, O3, PM10 and PM2.5 in 2017, and indicates cases
of non-compliance with the limit value for PM10 and target value for O3.
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Section 3.2 provides an overview of the challenges in relation to NO2, O3, PM10 and PM2.5, however,
current PaMs for improving air quality for the pollutants listed are not described within the NAPCP.
Charts are included in the NAPCP to illustrate air pollutant concentrations over a time series (2000-
2017 for O3 and 2002-2017 for PM10 and PM2.5). Maps are also included, illustrating the air quality
assessment zones (Figures 13-16 and Table 3 in the NAPCP).
3.4.3 Current transboundary impact of national emission sources
Section 3.3 of the NAPCP provides a quantitative overview of pollutant emissions from Slovenia
affecting neighbouring countries. Figures are provided for SO2, NOX and NH3 emissions (see Figures
17 – 20 of the NAPCP). The analysis has been produced by the Norwegian Meteorological Institute for
the year 2016 and shows that emissions with a transboundary effect have been decreasing since 2000,
in particular emissions of SO2. The maps show that affected countries include Czech Republic, Austria,
Hungary, Italy, Croatia, Poland, Germany, Lithuania, Belarus, Ukraine, Romania, Serbia and Bosnia
and Herzegovina.
There is no evidence of transboundary consultation activities being undertaken in the development of
the NAPCP.
Projected situation assuming no change in currently adopted
PaMs (M, O)
Under the WM scenario, all 2020-2029 emission reduction commitments are projected to be
achieved. The 2030 onwards commitments for NMVOC and PM2.5 are projected to be missed.
SO2, NOX and NH3 commitments are projected to be achieved (Table 4, section 4.1 of the
NAPCP).
Projected impacts on air quality improvements is provided in qualitative terms for NO2, PM2.5 and
PM10 up to 2030 (section 4.2 of the NAPCP).
In section 4.1 of the NAPCP, Slovenia provides an overview of the emissions reductions projected
under WM scenario reported for 2020, 2025 and 2030 and whether it meets the national emission
reduction commitment set in the NECD. In sum:
All 2020-2029 emission reduction commitments are projected to be achieved.
2030 onwards commitments for NMVOC and PM2.5 are projected to be missed with existing
measures (by 4 and 3 percentage points, respectively).
2030 onwards commitments for SO2, NOX and NH3 are projected to be met by 1 percentage point
or less.
As presented in section 2 of this report, the inventory year underpinning the projections is reported
(2017), but the year that the NAPCP projections were produced is not. However, based on the year of
the inventory data underpinning the projections, the NAPCP projections are judged in the review as
sufficiently up to date to reflect existing PaMs in the WM scenario.
With regards to air quality improvements, Slovenia shows the projected improvements in air quality for
NO2, PM2.5 and PM10 as percentage reductions of pollutant concentrations modelled for the year 2030
(section 4.2). Information is not presented for ground-level O3, despite the fact that incidences of non-
compliance are reported for O3 in 2017. The projected impacts on air quality are not described with
respect to the degree of compliance with EU air quality standards.
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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)
PaMs were submitted via the EEA PaM-tool on 25 November 2019. Information is also presented
in section 5 of the NAPCP.
13 PaMs (1 package of 5 individual PaMs and 8 individual PaMs) are considered to deliver
emission reductions from energy consumption, the transport sector and solvent use. The PaMs
will primarily reduce NMVOC and PM2.5 emissions. These are the pollutants for which 2030
onwards commitments are projected to be missed with existing measures.
Information is not provided for the expected quantified impacts of the PaMs on air pollutant
emissions, air quality and the environment.
3.6.1 Summary of the information reported
PaMs were submitted via the EEA PaM-tool on 25 November 2019. Information is also presented in
section 5 of the NAPCP. The assessment presented in this section is based on the information
submitted via the EEA-PaM tool as well as accompanying information reported in the main body of the
NAPCP.
Limited information is reported via the EEA PaM-tool. A total of 13 PaMs are considered for adoption:
seven relate to the combustion of wood, three to the transport sector and two to solvent use, as listed
below.
Limited information is also presented in the NAPCP. For each of the PaMs, information is provided as
follows: i) name and short description, ii) pollutants concerned, iii) objectives, iv) types of PaMs, v)
sectors concerned, vi) implementation period; vii) responsible authority; and viii) reference to planning
documents underlying the PaM.
In view of the limited information presented (the emission reductions are not quantified for individual or
packages of PaMs and the PaM description is brief), the PaMs are judged by the reviewers as not
credible. It is not feasible to confidently comment on whether the projected impacts on emissions are
realistic and achievable.
The PaMs considered are presented in the tables below, all have been selected for adoption.
Energy consumption (three individual PaMs and one package of five PaMs)
Reducing emissions from wood biomass boilers in households
More intensive promotion of replacement of old wood biomass combustion plants with modern wood
biomass installations (Eco label) or heat pumps
Restrictions on the sale of inefficient wood biomass installations, installation of a new plant by a
certified provider, with a mandatory demonstration of proper use of newly fitted equipment
Establish conditions for the professional functioning of chimney sweeping services, to introduce
professional supervision of the work of chimney sweeping services, to organise complementary
training courses for chimney sweeps
Awareness-raising and education of users of woody biomass devices in relation to adequate fuel and
proper burning, consequences of misfiring by using different communication channels
Demonstration projects of proper burning
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Energy consumption (three individual PaMs and one package of five PaMs)
Individual PaMs
Preparation of a programme to exchange devices and raise awareness among households of socially
weak households about the correct use of wood biomass installations
Incentives to install particulate filters on small combustion plants
Promoting the connection to district heating systems and the construction of small systems in areas
where forest cover is high
Transport (three individual PaMs)
Strengthening the incentives in the field of alternative powertrains in line with the alternative transport
action programme
Green areas in cities where only zero emission vehicles are allowed, including delivery vehicles and
buses.
Incentives for modal shift through the preparation of institutions’ mobility plans, reward for the use of
public passenger transport or non-motorised transport modes in organisations
Solvent use (two individual PaMs)
Improvement of the recording of emissions from the domestic solvents use (NFR code 2.D.3.a)
Collection of records for all chemicals
Notes: All PaMs considered have been selected for adoption.
3.6.2 Pollutants targeted and projected emission reductions
Section 5 of the NAPCP re-iterates the non-compliance projected for NMVOC and PM2.5 2030 onwards
commitments with existing measures and highlights that additional PaMs are needed to meet emission
reduction commitments.
According to the reporting via the EEA PaM-tool, PaMs target emission reductions of PM2.5 and
NMVOC. PaMs targeting the transport sector will also deliver emission reductions of NOX.
Information on the estimated quantified effect of the PaMs is not reported via the EEA PaM-tool or
presented in the NAPCP.
3.6.3 Coherence between the PaMs considered and policy priorities
Coherence between the additional PaMs and policy priorities is not reported via the EEA PaM-tool or
presented in the NAPCP.
3.6.4 Responsible authorities and timescales for implementation of PaMs considered
There is a good mixture of economic, regulatory, awareness raising, pollution control and planning
policy tools across the listed PaMs.
Implementation of the 13 additional PaMs considered would be overseen by a mixture of authorities,
including the Ministry of the Environment and Spatial Planning, the Ministry of Infrastructure and the
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Ecological Fund and the Statistical Office. As indicated in section 3.3, the Ministry of Environment and
Spatial Planning has an overall coordination role.
Planned implementation is scheduled to start in 2020 and finish in 2030 for all the PaMs considered.
3.6.5 Details of the methodology for evaluation and selection of PaMs
There is no information on the methodology for evaluation and selection of PaMs reported via the EEA
PaM-tool or presented in the NAPCP.
3.6.6 Estimation of costs and benefits of the individual PaM or package of PaMs
considered
No information is provided on the costs and benefits of the additional PaMs reported via the EEA PaM-
tool or presented in the NAPCP.
3.6.7 Impacts on air quality and the environment of individual PaMs or packages of
PaMs considered
Despite non-compliance with air quality standards for O3 and PM10 (see section 3.4.2 of this review
report), the impacts of additional PaMs considered on air quality improvements for these pollutants are
not reported via the EEA PaM-tool or presented in the NAPCP (either in relation to EU air quality
standards or the WHO air quality guidelines).
The policies selected for adoption by sector including
timetable for adoption, implementation and review and
responsible competent authority (M, O)
All PaMs have been selected for adoption according to the information presented in the NAPCP.
With the additional PaMs, Slovenia is nonetheless still projecting to miss the 2030 onwards
commitments for NMVOC and PM2.5.
3.7.1 Assessment of the credibility of the PaMs selected for adoption per sector
According to the information presented in the NAPCP, Slovenia has selected 13 PaMs for adoption. No
explanation of the choices made to select the PaMs is provided. According to reporting via the EEA
PaM-tool, none of the additional PaMs have been selected for adoption. It is unclear why this
discrepancy in reporting has occurred based on the information available in the NAPCP and via the
EEA PaM-tool.
The estimated emission reductions for these PaMs is not presented in the NAPCP. Furthermore, no
information is presented on how progress in implementation will be monitored, with no indicators or
targets defined. The PaMs selected for adoption will be implemented by national government and
municipal authorities together with support from local stakeholders including media agencies, fire
services and other professional associations.
The PaMs selected for adoption are discussed per sector below with reference to the information
presented in section 5 of the NAPCP as well as the information reported via the EEA PaM-tool.
Agriculture
Information concerning measures relating to agriculture, as listed in Part 2 of Annex III of the NECD are
included in the NAPCP showing that all mandatory measures and a set of optional measures are
existing PaMs in Slovenia (sections 3.1.4 and 5.2 of the NAPCP).
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An overview table provides information on the implementation of these measures (see Table 1 of the
NAPCP), including 1) National Advisory Code of Good Agricultural Practice for the Control of Ammonia
Emissions is drawn up by the State, 2) National nitrogen balances to monitor changes in total losses of
reactive nitrogen from agriculture, 3) Prohibition of the use of ammonium carbonate fertilisers and
reduction of ammonia emissions from fertilisation with mineral fertilisers and 4) Reduction of ammonia
emissions from the storage of livestock manure and fertilisation with livestock manure. For 3) and 4) a
list of PaMs is provided in the table.
No information is provided as to whether modifications have been made. No other agriculture related
PaMs targeting PM2.5 or black carbon are included in the NAPCP.
Energy consumption
PaMs cover energy consumption for domestic heating, relating to biomass boiler standards and their
use, as well as chimney sweeping services. PaMs also relate to access to district heating systems
and incentives to install particulate filters on small combustion plants.
For energy consumption, PaMs selected for adoption include a combination of policy instruments
(voluntary awareness raising campaigns, economic measures, regulatory intervention, and
monitoring). Based on the PaM descriptions, the NAPCP review finds that it is likely that this mix of
policy instruments can deliver emission reductions. Implementation is planned to start in 2020 and to
finish in 2030.
No emission reductions have been estimated for these PaMs. In accordance with the guidelines for
reporting PaMs in the EEA PaM-tool (2019)7, it is possible that estimated emission reductions have
not been reported for these PaMs because they are not intended to bring any emissions reduction by
themselves (i.e. emission reductions will only be achieved if standards are adhered to).
Transport
The limited description presented in the NAPCP for the individual PaM adopted to promote alternative
fuels means it is not possible to determine what this will entail. The other two PaMs selected for adoption
are aimed at supporting a modal shift from motorised modes of transport to non-motorised modes of
transport with the establishment of green areas in cities and other incentives.
PaMs selected for adoption to reduce emissions from transport include a combination of policy
instruments (economic, regulatory and fiscal measures, as well as awareness raising campaigns).
Implementation is planned to start in 2020 and to finish in 2030.
No emission reductions have been estimated for these PaMs.
Based on the descriptions of the PaMs targeting the transport sector, the NAPCP review finds that
these PaMs are more relevant to NOx emission reductions rather than PM2.5 (introducing mobility plans
to facilitate alternative fuels in transport and non-motorised transport).
Other
For solvent use, PaMs adopted relate to monitoring and reporting of emissions from the domestic
solvents use. It is unclear from the information presented how the PaMs will deliver emission
reductions. Implementation is planned to start in 2020 and to finish in 2030.
No emission reductions have been estimated for these PaMs. In accordance with the guidelines for
reporting PaMs in the EEA PaM-tool (2019)7, it is possible that estimated emission reductions have
not been reported for these PaMs because they are not intended to bring any emissions reduction by
themselves.
7 Aether and EEA (2019) Guidelines for reporting Policies and Measures in the EEA PAM-tool, under Directive (EU) 2016/2284 on the reduction of
national emissions of certain atmospheric pollutants (NEC Directive). http://cdr.eionet.europa.eu/help/necd/necd_guide_2019.pdf
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3.7.2 Feedback from the consultation undertaken
Slovenia does not report any views from the consultation with respect to the final selection and design
of the PaMs selected for adoption.
3.7.3 Sources of funding
No information on funding sources is reported in the NAPCP.
3.7.4 Coherence with plans and programmes set up in other relevant policy areas
For each of the PaMs selected for adoption, the underlying planning documents are reported which
establish coherence with air quality policy priorities (and related air quality plans) and other policies for
energy and transport (and related action plans). However, no further detail is provided.
Projected combined impacts of PaMs on emission
reductions, air quality and the environment and associated
uncertainties (where applicable) (M, O)
Under a WAM scenario, the 2030 onwards commitments for NMVOC and PM2.5 are projected
to be missed (section 6.1 of the NAPCP).
The emission projections provided by Slovenia follow a linear emission reduction trajectory.
Adjustments to the historical inventory data have been applied to NMVOC and NOX from
agricultural sources.
Slovenia provides a qualitative description of the expected impact on PM2.5, PM10 and NO2
concentrations by 2030 which indicates that only minor improvements are projected compared
to the WM scenario.
Slovenia does not provide information concerning the projected impacts on the environment.
3.8.1 Likelihood of achievement of projected emission reductions
According to the projections presented in the NAPCP, emission reductions under the WAM scenario
are projected to achieve the 2020-29 national emission reduction commitments. For 2030 onwards,
Slovenia is projected to miss the commitments for NMVOC and PM2.5 (as presented in section 6.1,
Table 11 of the NAPCP and summarised in section 2.2 of this report).
Conclusions from the NAPCP review on whether the projected emission reductions per pollutant are
likely to realise in practice are presented in Table 3-1.
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 No
No additional PaMs are
considered or adopted for this
pollutant.
n/a
NOX Yes No
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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?
No additional PaMs are
considered or adopted for this
pollutant according to the
information presented in the
NAPCP. According to information
reported via the EEA PaM-tool, the
PaMs targeting the transport
sector (introducing mobility plans
to facilitate alternative fuels in
transport and non-motorised
transport) are likely to also deliver
emission reductions of NOx.
For transport, the PaMs are intended
to support a modal shift, for which, the
estimated quantified impacts are not
presented in the NAPCP. Thus, it is
not possible to determine how likely
any emission reductions might be.
NMVOC Yes
Additional PaMs adopted target
the main sources of NMVOC
emissions which are solvent use
and energy consumption by
households (from burning of wood
biomass).
No
For solvent use, the PaMs rely on
monitoring and reporting of emissions
and there is uncertainty as to what
emission reductions this alone can
achieve.
For energy consumption, PaMs
adopted rely on the implementation of
standards to deliver emission
reductions.
In both cases, the estimated
quantified impacts are not presented
in the NAPCP. Thus, it is not possible
to determine how likely any emission
reductions might be.
NH3 No
No additional PaMs are
considered or adopted for this
pollutant.
n/a
PM2.5 Yes
PaMs adopted target combustion
of wood in energy consumption
and the transport sector as two
key emitting sources of PM2.5.
No
For transport, the PaMs are intended
to support a modal shift, for which, the
estimated quantified impacts are not
presented in the NAPCP. Thus, it is
not possible to determine how likely
any emission reductions might be.
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.
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3.8.2 Deviation from the linear trajectory for 2025
The NAPCP emission projections provided by Slovenia follow a linear emission reduction trajectory.
3.8.3 Use of flexibilities
The NAPCP states that adjustments to the historical inventory data have been applied to NMVOC and
NOX from agricultural sources in accordance with point 1 of Article 5 of the NECD. However, no
explanation is reported and the information provided in the NAPCP does not fulfil the requirements by
Part 4 of Annex IV of the NECD.
3.8.4 Projected impacts on air quality and the environment.
Slovenia provides a qualitative description of the expected impact on PM2.5, PM10 and NO2
concentrations by 2030 (see section 6.3). This section shows that the impact under a WAM scenario
on air quality is very small. The SHERPA tool has been used to model impacts of projected emission
reductions on air quality.
In section 6.3 Slovenia provided three maps to illustrate projected reductions in NO2, PM2.5 and PM10
concentrations under the WAM scenario (Figures 29-31 in the NAPCP). There is no information
regarding compliance with the EU limit and target values.
Slovenia does not provide information concerning the projected impacts on the environment.
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4 Conclusions and recommendations
Conclusions
The NAPCP was submitted on 10 October 2019, after the reporting deadline of 1 April 2019. The
common format has not been used in terms of its layout and content. However, the NAPCP follows the
structure of the common format in most cases. PaMs were submitted via the EEA PaM-tool on 25
November 2019.
It was reported in the NAPCP that delays in finalising the NAPCP were necessary to ensure coherence
with the NECP which was being prepared at the time. However, it is not clear from the information
presented in the final NAPCP how the NECP has been taken into account.
The completeness assessment conducted identified a few gaps in reporting relating to the policy
priorities described, information on additional PaMs and for the NAPCP projections. According to the
NAPCP review, the significance of the gaps identified is as follows:
Overall, the limited information presented for the additional PaMs considered and selected for
adoption is the most significant gap. The NAPCP does not present the estimated emission
reductions, or the expected impacts on air quality and the environment of the PaMs.
The year of NAPCP projections is not reported.
The NAPCP projections under a WM scenario show that Slovenia is projected to achieve its 2020-2029
national emission reduction commitments for all five NECD pollutants, but for 2030 onwards, NMVOC
and PM2.5 commitments are projected to be missed. Accordingly, information on additional PaMs
targeting NMVOC and PM2.5 is presented in the NAPCP.
There are differences between the projections (WM scenario) submitted under Article 10(2) and the
projections (WM scenario) presented in the NAPCP. The differences affect the projected compliance
for the NOx 2020-29 commitment and the SO2 2030 onwards commitment. In both cases, the
differences occur because the projected emission reductions as a percentage of the 2005 baseline year
are rounded up in the NAPCP projections but reported to two decimal points for the projections
submitted under Article 10(2). This allows the projected percentage emission reductions to meet the
percentage emission reduction commitments exactly according to the information presented in the
NAPCP, while missing the respective commitments according to the projections submitted under Article
10(2).
Based on the projections presented in the NAPCP, additional PaMs are not considered necessary for
SO2 and NOx.
The contradicting information reported via the EEA PaM-tool and the information presented in the
NAPCP makes it unclear if the additional PaMs have been selected for adoption. According to the
NAPCP a total of 13 PaMs are selected for adoption, targeting NMVOC and PM2.5 emissions. The extent
to which the PaMs can be judged to be credible is limited based on the minimal descriptions presented
and lack of estimated emission reduction data. Even with additional PaMs, Slovenia is not expected to
meet the 2030 onwards commitments for NMVOC and PM2.5. Further additional PaMs are required to
ensure these commitments can be met.
A positive highlight from the review of the NAPCP is that much of the optional content is presented
together with a detailed account of existing PaMs. This includes:
The detailed description of existing PaMs and implemented EU legislation which provides a good
basis for understanding progress achieved to date in reducing emissions to air as well as improving
air quality (which are presented with references to related programming documents). The additional
detail in Annex 1 demonstrates coherence with energy and climate policy priorities for existing PaMs
adopted.
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The use of graphics to portray current progress achieved and projected impact on air quality
improvements complements the detailed descriptions provided for existing PaMs.
Both existing and additional measures for agriculture listed in Annex III, Part 2 to the NECD are
reported in the NAPCP. This enables the NAPCP review to establish how mandatory measures in
the NECD have been adopted.
Additional PaMs are presented together with their respective underlying planning documents which
demonstrates how coherence with air quality policy priorities and relevant energy and transport
policy priorities is intended to be achieved.
The projections under a WAM scenario were not submitted under Article 10(2). Thus, risk of non-
compliance (as presented in the risk assessment in Appendix 2 to this report) is determined according
to the Article 10(2) projections under a WM scenario. According to the risk assessment therefore,
Slovenia is at a high risk of non-compliance with 2020-29 NOx commitment and the 2030 onwards
commitments for SO2, NMVOC, NH3 and PM2.5. .
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
Slovenia is required to use the common format for presenting its NAPCP.
The NAPCP projections under a WAM scenario show that even under the WAM scenario 2030
commitments for NMVOC and PM2.5 are projected not to be met. Further additional PaMs should
be considered and selected for adoption to ensure that the respective commitments can be met.
The date of the NAPCP projections is not reported. Furthermore, the review uncovered differences
between them and the projections submitted under Article 10(2). To ensure compliance (and to help
explain the differences identified), the date of the NAPCP projections is required.
Estimated emission reductions are not reported for the PaMs considered and information is not
provided for the impact on air quality and the environment. To ensure compliance, Slovenia should
provide all minimum content for the PaMs considered.
Areas for improvement
In accordance with the NECD, where appropriate, transboundary consultations shall be conducted
(Article 6(6)). Member States should provide links to relevant website(s) on the consultation
undertaken (section 2.1.1. of the common format). Slovenia identifies transboundary air pollution
transfers with neighbouring countries. However, evidence is needed to show that consultation on
the NAPCP has been undertaken with the affected neighbouring countries or if no consultation has
been undertaken then on the reasons why.
Based on the emission reductions presented in the NAPCP for the WM scenario the 2020-29 NOx
commitment and the 2030 SO2 commitment are projected to be achieved. However the review has
found that if the emission reductions were not rounded to a zero decimal point, these commitments
would be missed. According to the conclusions of the review of Article 10(2) projections, these
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emission reduction commitments are also projected to be missed. It is recommended that for future
revisions of the NAPCP Slovenia does not round the figures to zero decimal point and more
precisely draws conclusions on projected compliance or non-compliance. In addition it is
recommended that Slovenia adopts additional PaMs to increase the margin by which the respective
commitments for NOx and SO2 can be achieved.
Slovenia describes the projected improvements in air quality for NO2, PM2.5 and PM10 in 2030.
However, information could also be provided on ground-level O3 in view of the incidences of non-
compliance with the EU target values in 2017.
The contradicting information reported via the EEA PaM-tool and the information presented in the
NAPCP makes it unclear if the additional PaMs have been selected for adoption. It is recommended
that reporting is aligned to avoid uncertainty.
Encouragement
According to Annex I of Commission Implementing Decision (EU) 2018/1522, reference can be
made to the WHO air quality guidelines. This optional content could be presented in the NAPCP to
strengthen the policy priorities described.
Optional PaMs targeting NH3 in the agricultural sector as set out in Part 2, section A of Annex III to
the NECD are reported. However, this is not done for PM2.5 and black carbon (Part 2, section B).
Slovenia is encouraged to add this information.
Slovenia is encouraged to include details on costs and benefits of PaMs considered for adoption.
Slovenia reports on its use of flexibilities in section 6.2 indicating that it wishes to adjust historic
inventories. Optional content on the details of such adjustments and its impact on compliance could
be presented in the NAPCP.
Slovenia does not provide information concerning the projected impacts on the environment.
Slovenia is encouraged to present this optional content (section 2.8.5 of the common format).
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Appendix 1 Completeness assessment
A completeness assessment was conducted to identify gaps in reporting according the minimum
content minimum content as required by the Commission Implementing Decision (EU) 2018/1522)8
laying down a common format of the NAPCP. 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 Amber
The title, date and responsible authority (the Ministry of Environment and Spatial Planning) are presented in the NAPCP. No website links are provided to access the NAPCP and supporting documentation online, including information on consultation(s).
2.3.1 Policy priorities and their
relationship to priorities set in other
relevant policy areas
Amber
Slovenia reports emission reduction policy priorities (section 2.1.1) and their relation to priorities set in air quality (section 2.1.2), climate change and energy (section 2.1.3), and agriculture and transport (section 2.1.4). Policy priorities for industry are not reported.
2.3.2 Responsibilities attributed to
national, regional and local authorities Green
Responsibilities attributed to authorities at all levels of governance are reported (section 2.2).
2.4.1 Progress made by current PaMs in
reducing emissions, and the degree of
compliance with national and Union
emission reduction obligations
Green
Progress by current PaMs is reported by pollutant (section 3.1). References are incomplete (titles, page and chapter numbers and weblinks are not provided).
2.4.2 Progress made by current PaMs in
improving air quality, and the degree of Green
Slovenia identifies challenges for air quality (section 3.2). Compliant air quality zones with EU air quality objectives are reported for NO2, O3, PM10 and PM2.5. References are
8 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.
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Reference to the NAPCP common
format
RAG
Rating Explanation
compliance with national and Union air
quality obligations
incomplete (titles, page and chapter numbers and weblinks are not provided).
2.4.3 Where relevant, current
transboundary impact of national emission
sources
Green Slovenia describes the current transboundary impact of domestic emission sources for all NECD pollutants (section 3.3).
2.5.1 Projected emissions and emission
reductions (WM scenario) Amber
Emission projections have been reported for 2005 base year, 2020, 2025 and 2030, complete with the minimum content required (section 4.1). The date of the projections is not provided.
2.5.2 Projected impact on improving air
quality (WM scenario) Amber
Projected improvements in air quality for NO2, PM2.5 and PM10 in 2030 are described but not for O3. The projected degree of compliance with EU air quality standards is not presented. References are incomplete (titles, page and chapter numbers and weblinks are missing).
2.6.1 Details concerning the PaMs
considered in order to comply with the
emission reduction commitments
(reporting at PaM level)
Amber
The EEA PaM-tool has been used for reporting. Emission reductions from the PaMs considered for adoption are not quantified.
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
Red Impact on air quality and the environment is not reported in the NAPCP or via the EEA PaM-tool.
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
Green
Mandatory measures for agriculture sector as listed in Part 2 of Annex III of the NECD are already implemented according to the information presented in the NAPCP (section 5.2). More detail is provided for PaMs targeting NH3 emission reductions. (Table 1 in section 3.1.4 of the NAPCP). Accordingly, no information is reported via the EEA PaM-tool for these measures.
2.7.1 Individual PaMs or package of PaMs
selected for adoption and the competent
authorities responsible
Amber
Slovenia reports that all additional PaMs are selected for adoption (section 6 of the NAPCP). Information on additional PaMs selected for adoption is thus presented in the section 5 of the NAPCP.
However, reporting via the EEA PaM-tool states that none of the PaMs have been selected for adoption. Thus, it is unclear whether the PaMs have been selected or not.
2.7.2 Assessment of how selected PaMs
ensure coherence with plans and
programmes set up in other relevant
policy areas
Amber
Relevant air quality, energy and transport policies and programmes are presented for those PaMs selected for adoption, but no assessment of how selected PaMs ensure coherence with air quality objectives or with
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Reference to the NAPCP common
format
RAG
Rating Explanation
other relevant plans and programmes is presented in the NAPCP.
2.8.1 Projected attainment of emission
reduction commitments (WAM) Amber
Emission projections have been reported for 2005 base year, 2020, 2025 and 2030, complete with the minimum content required (section 6.1). The date of the projections is not provided.
2.8.2 Non-linear emission reduction
trajectory N/A
The emissions projected by Slovenia expect to follow a linear emission reduction trajectory.
2.8.3 Flexibilities Green
Slovenia indicates that it will use the flexibility in accordance with the first point of Article 5 of the NECD on adjustment of historical inventory.
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 Green Slovenia provides a two-page executive summary (section 1).
2.3.1 Policy priorities and their
relationship to priorities set in other
relevant policy areas: Reference to WHO
guideline values
White
Slovenia does not refer to the WHO guideline values with respect to the air quality priorities reported.
2.3.2 Responsibilities attributed to
national, regional and local authorities:
Source sectors under the responsibility of
the authority
Green Slovenia reports where competent authorities are responsible for specific source sectors (section 2.2).
2.4.1 Progress made by current PaMs in
reducing emissions, and the degree of
compliance with national and Union
emission reduction obligations: Provision
of graphics
Green Graphics are used to illustrate emission reductions per pollutant and per sector.
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Reference to the NAPCP common
format
RAG
Rating Explanation
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
Charts are used to illustrate progress over a timeseries. A map is used to illustrate the air quality zones. Concentrations of air quality pollutants are described in relation to specific air quality zones, but progress is not described for current PaMs.
2.4.3 Methodologies and data used to
show the current transboundary impact of
national emission sources
White The data source is provided but no additional description is included.
2.5.1 Associated uncertainties of the
projected emissions and emission
reductions (WM scenario)
Green Slovenia outlines the associated uncertainties for the WM projections by pollutant (section 4.1).
2.5.2 Quantitative data on the projected
impact on improving air quality (WM
scenario)
White Quantitative data to describe the projected degree of compliance with EU air quality objectives is not presented.
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 Additional PaMs do not target pollutants beyond the scope of the NECD.
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 Information on costs and benefits is not reported.
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 for optional measures relating to agriculture listed in Part 2 of Annex III of the NECD is presented in Table 1 in section 3.1.4 of the NAPCP for NH3 emission reduction measures only. Accordingly, no information is reported via the EEA PaM-tool for these measures.
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 No comments from the consultation are reported in the NAPCP. No interim targets or indicators are reported in the NAPCP.
2.7.2 Explanation of the choice of
selected measures White The reasons for the selection of PaMs is not
presented in the NAPCP.
2.8.4 Projected improvement in air quality
(WAM) Green
Slovenia presents a qualitative description of the expected impact on PM2.5, PM10 and NO2 concentrations by 2030.
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Reference to the NAPCP common
format
RAG
Rating Explanation
2.8.5 Projected impacts on the
environment (WAM) White
Information on the projected impacts of PaMs on the environment is not presented in the NAPCP.
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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 Yes Yes
WAM NR NR NR NR NR
Are the projections
submitted under Article
10(2) considered to be of
good quality?
WM No Partially Partially Partially Partially
Are the NAPCP projections
consistent with the latest
projections submitted
under Article 10(2)?
WM Partially No Partially Partially Partially
WAM n/a NR n/a n/a NR
Does the NAPCP present
credible additional PaMs
selected for adoption?
WAM n/a No n/a n/a n/a
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 (67) No (-1) Yes (12) Yes (8) Yes (11)
WAM NR NR NR NR NR
Risk of non-compliance M H M M M
Additional comments on
high risk scores
The review has concluded that Slovenia is at a high risk of non-
compliance with the emission reduction commitments for NOX for
2020-2029. This is driven by:
Slovenia projecting non-compliance with the NOx emission reduction commitment under the WM scenario submitted under Article 10(2)
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Lack of WAM scenario demonstrating how the commitment will be achieved.
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 No Yes No Yes No
WAM NR NR NR NR NR
Are the projections
submitted under Article
10(2) considered to be of
good quality?
WM No Partially Partially Partially Partially
Are the NAPCP projections
consistent with the latest
projections submitted
under Article 10(2)?
WM No Yes Partially Partially Partially
WAM NR n/a NR n/a NR
Does the NAPCP present
credible additional PaMs
selected for adoption?
WAM n/a No No n/a No
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 (-6) No (2) No (-35) No (2) No (-4)
WAM NR NR NR NR NR
Risk of non-compliance H M H H H
Additional comments on
high risk scores
The review has concluded that Slovenia is at a high risk of non-
compliance with the emission reduction commitments for SO2,
NMVOC, NH3 and PM2.5 for 2030 onwards.
For SO2, NMVOC and PM2.5 this is driven by:
Slovenia projecting to miss the emission reduction commitment according to the projections submitted under Article 10(2) under WM scenario
Lack of WAM scenario demonstrating how the commitment will be achieved.
For NH3, this is driven by:
Minor improvements to the projection’s methodology recommended in the review.
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Minor inconsistencies between the projections reported under Article 10(2) and those presented in the NAPCP.
Small margin of compliance with the emission reduction commitment.
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