Sustainable Cities Implementation Framework – Air Quality AIR QUALITY DEEP DIVE Bulgaria, Croatia, Poland and Romania Sustainable Cities Implementation Framework February 2022 1 Disclaimer This volume is a product of the staff of the International Bank for Reconstruction and Development/ The World Bank. The findings, interpretations, and conclusions expressed in this paper do not necessarily reflect the views of the Executive Directors of The World Bank or the governments they represent. The World Bank does not guarantee the accuracy of the data included in this work. The boundaries, colors, denominations, and other information shown on any map in this work do not imply any judgment on the part of The World Bank concerning the legal status of any territory or the endorsement or acceptance of such boundaries. Copyright Statement The material in this work is subject to copyright. Because The World Bank encourages dissemination of its knowledge, this work may be reproduced, in whole or in part, for noncommercial purposes as long as full attribution to this work is given. Any queries on rights and licenses, including subsidiary rights, should be addressed to World Bank Publications, The World Bank Group, 1818 H Street NW, Washington, DC 20433, USA; fax: 202-522- 2625; e-mail: pubrights@worldbank.org. © 2022 Global Practice on Urban, Disaster Risk, Resilience, and Land. The World Bank Group 1818 H Street NW Washington, DC 20433 USA www.worldbank.org/urban Cover Photos Aerial view of bridge over Dubrovnik port, Croatia: © Dubrovnik Port Authority Pollution obscures the view of Warsaw from the Poniatowski Bridge, Poland. Photo: © EPA The Rovinari lignite power plant in Rosia de Jiu, Romania. Photo: © Bankwatch. 2 Sustainable Cities Implementation Framework – Air Quality TABLE OF CONTENTS Executive Summary................................................................................................................................. 9 Introduction .......................................................................................................................................... 15 What are the pollutants of concern? ................................................................................................ 16 Impacts of poor Air Quality ............................................................................................................... 17 COVID-19 – Impacts on air quality .................................................................................................... 20 European and National legislation and Frameworks ........................................................................ 21 Importance of good air quality for sustainable cities – Challenges for Delivery .............................. 26 Recommendations ............................................................................................................................ 29 BULGARIA .............................................................................................................................................. 32 Urban Context ................................................................................................................................... 32 Emission trends ................................................................................................................................. 32 Trends by key source sector .............................................................................................................. 34 Air Quality Trends.............................................................................................................................. 37 Current status and Gap Analyses ...................................................................................................... 41 Recommendations ............................................................................................................................ 47 CROATIA ................................................................................................................................................ 49 Urban Context ................................................................................................................................... 49 Emission trends ................................................................................................................................. 49 Trends by Key source sector ............................................................................................................. 51 Air Quality Trends.............................................................................................................................. 54 Current status and Gap Analyses ...................................................................................................... 58 Recommendations ............................................................................................................................ 60 POLAND ................................................................................................................................................. 63 Urban Context ................................................................................................................................... 63 Emission trends ................................................................................................................................. 63 Trends by Key source sector ............................................................................................................. 65 Air quality trends ............................................................................................................................... 68 Current status and Gap Analyses ...................................................................................................... 71 Recommendations ............................................................................................................................ 76 ROMANIA .............................................................................................................................................. 78 Urban Context ................................................................................................................................... 78 Emission trends ................................................................................................................................. 79 Trends by Key source sector ............................................................................................................. 80 Air Quality Trends.............................................................................................................................. 84 Current status and Gap Analyses ...................................................................................................... 87 Recommendations ............................................................................................................................ 89 Appendix ............................................................................................................................................... 91 3 LIST OF FIGURES Figure 1: Total NOx emissions timeseries by sector for Bulgaria.......................................................... 34 Figure 2: Total PM2.5 emissions timeseries by sector for Bulgaria ........................................................ 34 Figure 3: Total energy supply in Bulgaria by energy source, 1990-2019 .............................................. 35 Figure 4: Road transport fuel consumption in Bulgaria by fuel type, 1988-201945 ............................ 36 Figure 5: Residential fuel consumption in Bulgaria by fuel type, 1990-201945 ................................... 37 Figure 6: PM10 measurement data and measurement locations in Bulgaria........................................ 38 Figure 7: NO2 measurement data and measurement locations in Bulgaria ......................................... 39 Figure 8: BaP measurement data and measurement locations in Bulgaria ......................................... 39 Figure 9: Summary of national and local NAQIP and NAPCP measures ............................................... 43 Figure 10: Total NOx emissions timeseries by sector for Croatia ......................................................... 51 Figure 11: Total PM2.5 emissions timeseries by sector for Croatia ....................................................... 51 Figure 12: Total energy supply in Croatia by energy source, 1990-2019 ............................................. 52 Figure 13: Registered vehicle numbers in Croatia, 1990-201975 .......................................................... 53 Figure 14: Residential fuel consumption by fuel type in Croatia, 1990-201975 .................................... 54 Figure 15: PM10 measurement data and measurement locations in Croatia ....................................... 55 Figure 16: NO2 measurement data and measurement locations in Croatia......................................... 55 Figure 17: BaP measurement data and measurement locations in Croatia ......................................... 56 Figure 18: Total NOx emissions timeseries by sector for Poland ......................................................... 65 Figure 19: Total PM2.5 emissions timeseries by sector for Poland ........................................................ 65 Figure 20: Primary energy consumption [Mtoe] by source in Poland 1973 – 2015101 ......................... 66 Figure 21: Heat Production [Mtoe] by Source in Poland in the Period 1973 – 2015 ........................... 67 Figure 22: PM10 measurement data and measurement locations in Poland........................................ 68 Figure 23: NO2 measurement data and measurement locations in Poland ......................................... 69 Figure 24: BaP measurement data and measurement locations in Poland ......................................... 69 Figure 25: Total NOx emissions timeseries by sector for Romania ...................................................... 80 Figure 26: Total PM2.5 emissions timeseries by sector for Romania..................................................... 80 Figure 27: Total energy supply in Romania by energy source, 1990-2019 ........................................... 81 Figure 28: Number of vehicles and fleet composition in Romania, 1990-2019 128............................... 81 Figure 29: Fuel consumption for road transport by fuel type in Romania, 1990-2019 128 ................... 82 Figure 30: Fuel consumption within residential heating in Romania, 1990-2019 128 ........................... 83 Figure 31: PM10 emissions by residential heating fuel in Romania, 2000-2019 128............................... 83 Figure 32: NOx emissions by residential heating fuel in Romania, 2000-2019 128................................ 84 Figure 33: PM10 measurement data and measurement locations in Romania .................................... 85 Figure 34: NO2 measurement data and measurement locations in Romania ...................................... 85 Figure 35: BaP measurement data and measurement locations in Romania ...................................... 86 4 Sustainable Cities Implementation Framework – Air Quality LIST OF TABLES Table 1: National emissions reduction commitments for Bulgaria, Croatia, Poland and Romania ...... 24 Table 2: Total pollutant emissions for Bulgaria, 1990-2019 ................................................................. 33 Table 3: Percentage of urban population in Bulgaria exposed to concentrations above EU standards .............................................................................................................................................................. 40 Table 4: Monitoring stations used to report data to the European Environment Agency ................... 41 Table 5: Pollutant emission and source sector trends in Croatia, 1990-2019 ...................................... 50 Table 6: Percentage of urban population in Croatia exposed to concentrations above EU standards 56 Table 7: Monitoring stations used to report data to the European Environment Agency ................... 57 Table 8: Pollutant emissions and key sectors for Poland, 1990 and 2019............................................ 64 Table 9: Percentage of urban population in Poland exposed to concentrations above EU standards 70 Table 10: Monitoring stations used to report data to the European Environment Agency ................. 70 Table 11: Total pollutant emissions for Romania, 1990-2019 .............................................................. 79 Table 12: Percentage of urban population in Romania exposed to concentrations above EU standards .............................................................................................................................................................. 86 Table 13: Monitoring stations used to report data to the European Environment Agency ................. 87 Table 14: Air Quality Standards for the Protection of Human Health (Ambient Air Quality Directive) 91 Table 15: Revised WHO Global Air Quality Guidelines (2021) .............................................................. 92 LIST OF BOXES Box 1: Road transport in Sofia .............................................................................................................. 36 Box 2: Residential emissions in Sofia 49 ................................................................................................. 37 Box 3: Sofia’s action plan to reduce emissions of PM10 and achieve AAQD standards....................... 44 Box 4: EBRD Green Cities Program in Bulgaria ..................................................................................... 44 Box 5: Funding sources for Sofia's Green City Action Plan ................................................................... 47 Box 6: City-Specific Monitoring: Croatia ............................................................................................... 57 Box 7: City Scale Monitoring: Poland .................................................................................................... 70 Box 8: Regional and city-level actions to improve air quality in Poland: Katowize, Poznan, and Warsaw .............................................................................................................................................................. 74 5 ACKNOWLEDGEMENTS This is a supporting paper for a larger analytical project (Sustainable Cities Implementation Framework) conducted in Bulgaria, Croatia, Poland and Romania. This report was produced by a team led by Yondela Tembakazi Silimela (Senior Urban Specialist, Urban, Disaster Risk, Resilience and Land Global Practice – UDRRL) and supported by Noriko Oe (Senior Urban Specialist, UDRRL) and Carli Bunding Venter (Senior Urban Specialist, UDRRL). Technical experts to the report include Ben Grebot (Air Quality expert), with support from Damaris Bangean (Consultant, UDRRL). The team would also like to thank peer reviewers Sameer Akbar (Senior Environmental Specialist) and Vasil Zlatev (Air Quality expert) for the excellent feed-back provided. 6 Sustainable Cities Implementation Framework – Air Quality ABBREVIATIONS AND ACRONYMS AAQD Ambient Air Quality Directive ANPM National Agency for Environmental Protection (Romania) AQ Air Quality AQM Air Quality Management BaP Benzo(a)pyrene BAT Best Available Techniques BC Black carbon BREF BAT Reference document CAP Clean Air Programme (Poland) CO Carbon monoxide CLRTAP Convention on Long-Range Transboundary Air Pollution CNG Compressed natural gas EAP Environment Action Programme EC European Commission EEA European Environment Agency EIR Environmental Implementation Review EPHA European Public Health Alliance ESIF European Structural and Investment Funds EU European Union GCAP Green City Action Plan GDP Gross domestic product GHG Greenhouse gas HDV Heavy duty vehicle IARC International Agency for Research on Cancer IEA International Energy Agency IED Industrial Emissions Directive IIR Informative Inventory Report LCP Large Combustion Plant LDV Light duty vehicle LEZ Low emission zone LPG Liquid petroleum gas MCPD Medium Combustion Plant Directive MoEW Ministry of Environment and Water (Bulgaria) NAPCP National Air Pollution Control Programme NAQIP National Air Quality Improvement Program (Bulgaria) NECD National Emission reduction Commitments Directive NGO Non-governmental Organization NMVOC Non-methane volatile organic compounds NO2 Nitrogen dioxide NOx Nitrogen oxides OECD Organization for Economic Co-operation and Development OPE Operational programme “Environmentâ€? O3 Ozone PAH Polycyclic aromatic hydrocarbons PaMs Policies and measures PAQI Polish Air Quality Index PM Particulate matter PM10 Particulate matter less than 10 micrometres in diameter 7 PM2.5 Particulate matter less than 2.5 micrometres in diameter SO2 Sulphur dioxide WHO World Health Organization WIOS Voivodeship Inspectorates of Environmental Protection ZEV Zero Emission Vehicle 8 Sustainable Cities Implementation Framework – Air Quality EXECUTIVE SUMMARY The World Bank is developing a Sustainable Cities Implementation Framework for Europe and Central Asia to inform World Bank and other development partners’ ongoing support to national and sub-national authorities in pursuit of Sustainable Cities. As part of this work, preliminary assessments were conducted in four countries (Bulgaria, Croatia, Poland and Romania), which identified the need for deep dive analytics on three topics (Air Quality, Spatial Form and Solid Waste Management). This report explores air quality challenges in urban areas, focusing on existing data, identifying contributing factors to poor air quality, and providing recommendations (implementation support areas) to improve air quality in Bulgaria, Croatia, Poland and Romania. Air pollution has a major impact on the sustainability of an urban area. It is a significant cause of premature death and morbidity, representing the single, largest environmental health risk in Europe. People in the larger cities tend to be exposed to higher levels of nitrogen dioxide due to emissions from road traffic. In central and eastern Europe, air quality is poor in many areas, especially in urban settings, and the burning of solid fuels for domestic heating and in industry results in public exposure to the highest concentrations of particulate matter and polycyclic hydrocarbons. As urban areas have higher levels of most pollutants, and a growing proportion of Europe’s population live in urban settings, there is a strong justification to focus the development of interventions to address air quality within cities. A "Deep Diveâ€? analysis has been carried out for 12 cities in the four countries identified above. Some of the key messages from this analysis are summarized below. Key Messages ï‚· Air pollution plays an important role in the sustainability of urban environments and affects multiple levels of society in differing ways. There are substantial impacts upon human health, but there are also important links to climate change and opportunities for co-benefits. There are substantial economic and social costs associated with these impacts. ï‚· Environmental conditions are not the same everywhere, and there are substantial disparities in exposure to air pollution within urban areas. In many European cities, there is a disproportionate exposure to higher pollution levels in the lower socio-economic groups, which may also be more susceptible to pollution. ï‚· Within cities, the principal local sources of pollution are road traffic and domestic/commercial/industrial combustion. For road transport, the vehicle fleets in the cities and countries considered within this report are typically much older than the EU average and there has been very limited uptake of low emission and electric vehicles. The latter appears to be due to a lack of financial incentives for the purchase of such vehicles as well as limited supporting infrastructure e.g. charging points for electric vehicles. For domestic/commercial/industrial combustion, the main challenge relates to the continued use of high levels of solid fuels (e.g. coal) for heating leading to high levels of air pollution and smog events during the heating season. 9 ï‚· Cities are also subject to pollution arising from sources outside of the urban scale, such as agriculture, and transport of pollutants over many hundreds of kilometers arising from other countries, both of which urban authorities may have no control over. ï‚· The overall air quality policy strategy of the EU is directed towards meeting the air quality guideline values of the World Health Organization (WHO) in the coming decades. EU air pollution policy follows a twin-track approach: by setting legal limits for concentrations of air pollutants and by establishing agreements and standards to reduce emissions at source, i.e. national emission reduction commitments (total emissions) and sector-specific sources. Whilst EU policy provides a strong framework for air quality management, EU Member States, and local and regional governments within them, are expected to take further actions in order to be able to meet the air quality standards and reduce the health impacts of air pollution. ï‚· Whilst air quality has generally improved across the EU, there are still many cities where the standards set in the Ambient Air Quality Directives (AAQD) for the protection of human health are exceeded. The principal pollutants of concern are nitrogen dioxide (NO2), fine particulate matter (PM10 and PM2.5) and ozone. Within eastern European cities, concentrations of carcinogenic Polycyclic Aromatic Hydrocarbons (including Benzo(a)Pyrene, BaP) are also of concern. The current air quality status for each of the countries considered within this report is summarized below: o Bulgaria is one of the EU Member States with the poorest air quality in urban areas, with high levels of urban population exposure to particulate matter resulting in significant pollution-related deaths and years of life lost. According to the European Environment Agency (EEA), air pollution was responsible for about 14,000 premature deaths in Bulgaria in 2015. Bulgaria has twice been referred to the Court of Justice of the European Union (most recently in December 2020) for continued exceedances of the annual and daily mean limit values for PM10. o For Croatia, the EEA estimated that in 2015, around 5,000 premature deaths could be attributed to air pollution. Croatia has reported a number of exceedances of the EU air quality limit and target values including those set for PM10, PM2.5 and BaP. As a result of these infringements, the European Commission has urged Croatia to take additional actions to comply (October 2020), and noted that measures taken to minimize air pollution were insufficient to keep exceedance periods as short as possible o Poland has some of the most polluted cities in the EU with some of the highest concentrations of PM10 and PM2.5. The EEA estimated that in 2019 close to 50,000 premature deaths were attributable to exposure to air pollution. Poland was referred to the Court of Justice of the EU by the European Commission in 2015 over continued exceedance of the daily mean limit value for PM10, and was ruled to be in breach of its obligations in 2018. Moreover, BaP Target Values have been continuously exceeded throughout the Polish territory; BaP is strongly associated with poorly controlled combustion, such as domestic coal burning. o For Romania, the EEA estimated that in 2015, around 27,000 premature deaths were attributable to exposure to air pollution. Concerns have been raised that the issue of air pollution is being underestimated due to inadequate monitoring in the country. The European Commission has sent formal letters (in 2017 and again in 2019) to Romania concerning systemic failures to monitor pollution across its territory in compliance with the AAQD. In addition, the Commission referred Romania to the European Court of 10 Sustainable Cities Implementation Framework – Air Quality Justice in 2018 for exceeding PM10 levels, and separately in 2021 for failing to produce a National Air Pollution Control Programme as required by the National Emissions Reduction Commitments Directive. ï‚· National-regional-local governance structures vary considerably between countries, as do the powers and responsibilities devolved to the city scale. Local and regional authorities do not always feel enabled and/or have the necessary capacity and resources to take further necessary actions. ï‚· There are many challenges to improving air quality in urban areas. These include: o Lack of collaboration and knowledge sharing between different levels of governance at the local, regional and national scales. o The failure of EU or national policies to deliver the expected reduction to emissions. o Governance issues, particularly at the local level where further actions required to improve air quality are impeded by mandate limits, uncertainties, and lack of political will. o Lack of public acceptance and overcoming challenges to mitigation measures. o Lack of guidance or local capacity (human resources and financial) to evaluate and implement interventions at the local level. ï‚· Tackling air pollution successfully requires a mix of policies and investments, including complementary ‘sticks and carrots’. No single approach will be able to reduce air pollution from all sources. Air quality management is complex and requires national, regional and local level actors to be working in harmony. A good starting point is to ensure that each of these structures has the resources, knowledge, and incentive to engage and take action, and is subsequently held accountable against measurable outcomes. ï‚· Measures to improve air quality can have significant co-benefits for other areas including (but not limited to) climate change (reduced emissions of greenhouse gases), noise and water quality. In addition, actions in these areas can also have co-benefits for air quality if designed appropriately although there can be disbenefits if certain measures are adopted without consideration for air quality e.g. the historic push for use of diesel vehicles, biomass burning, etc. Recommendations This deep dive has identified a series of recommendation to address the key urban air quality challenges in the countries of interest. These are summarized against the following three main areas: policy and legislation, institutions and capacity, and finance. Policy and legislation There is a broad body of EU legislation covering air quality and emissions – including source specific regulations – which has been transposed into national legislation. This provides an effective framework for managing and improving air quality. However, there appear to be some gaps in relation to compliance with this legislation (e.g. exceedances of EU air quality standards) primarily due to limitations in the development and implementation of additional local, regional and national policies and measures to supplement and support EU policy. For example, in a number of cities in the countries considered in this deep dive, the limit values for NO2 and PM10 are exceeded due to road transport and domestic sources, and the target values for PAH are exceeded due to solid fuel use in 11 domestic heating and energy generation. Whilst EU policy provides some contribution to reducing emissions from these sources (e.g. EURO vehicle emission standards for new vehicles), further local (and/or national) measures are required in order to further reduce emissions. For domestic sources, there are a number of possible policies and measures that could be considered, including the following: ï‚· Banning the burning of all solid fuels in domestic properties (or poor-quality solid fuels as part of a phase out); this could be implemented via a ban on the sale of such fuels to domestic customers. ï‚· Grants and/or other incentives to support the replacement of solid fuel boilers / stoves with gas or electric boilers / stoves or implementation of district heating schemes, focusing initially on older stoves and boilers that do not meet the European Eco-design standards. For road transport, there are a number of additional measures that could be considered, including the following: ï‚· Policies and measures to increase the uptake of low emission and electric vehicles, such as: o Scrappage schemes to incentivize phase-out of the older, more polluting vehicles. o Low emission / clean air zones restricting all, or the most polluting vehicles, from air quality hotspots. o Grants and/or other incentives (e.g. differential taxation) to incentivize the purchase of low emission or fully electric vehicles. o Investments in the necessary infrastructure to support switching to electric vehicles (e.g. charging infrastructure) ï‚· Policies and measures to reduce vehicle activity, such as: o Improvements to public transport systems. o Improved cycling and walking infrastructure. o Communication and education schemes. For both road transport and domestic sources, a number of the policies and measures described above could be considered in combination, for example the introduction of a low emission zone combined with financial incentives to support the purchase of low emission vehicles. European legislation also requires minimum standards in terms of the quality and quantity of air quality monitoring. Concerns have been raised, by the European Commission and others, that these minimum standards are not being met in some of the countries considered in this deep dive. However, a greater range of evidence support tools are required to develop and successfully direct interventions to improve air quality, to ensure they are targeted at the areas of greatest need. While there is some evidence that these tools are being supported, such as a forthcoming small sensor network in Warsaw, greater assistance will be needed to ensure that the required monitoring, modelling and emissions assessment tools are available at the city scale. Finally, there appear to be some governance issues between local, regional and national authorities hindering the development and uptake of the additional measures required to improve air quality. These are discussed further below. 12 Sustainable Cities Implementation Framework – Air Quality Institutions and capacities In order to effectively develop and implement air quality policy, it is important that national, regional and local authorities can deliver on their own tasks and work effectively with each other within a multi-level governance system. Whilst there is already a well-developed policy framework in place (albeit with a need for further local, regional and/or national actions), there are a number of challenges in relation to institutional capacity and governance . The European Commission’s Environmental Implementation Review (EIR)1 has identified – for some of the countries considered in this report – major governance issues linked to government effectiveness and regulatory quality. Issues related to rule of law and control of corruption have also been identified in some of the countries. Furthermore, limited resources within local municipalities can impact on their ability to develop and implement effective policies and take actions to improve air quality. Finally, challenges with information sharing and co-ordination (between government bodies at all levels and with other stakeholders) have been identified. Each of these challenges – individually and collectively – can hinder the effective and efficient development and implementation of robust air quality (and other) policies. Potential recommendations to address some of the challenges include the following: ï‚· Increased human and financial resources at the municipality level to ensure they can prepare and implement effective air quality action plans and measures. Increased resources can also support municipalities with accessing wider funding sources due to the complexity and resources required for applications e.g. for European structural funds. ï‚· Sharing of resources between municipalities including access to relevant tools (e.g. for air quality modelling and emission inventories). This could include the establishment of centralized shared toolkits, materials and/or training materials. ï‚· Capacity building support to improve technical capabilities for air quality assessment and management e.g. for modelling and emissions inventories, designing new policies. ï‚· Improve vertical (between different levels of government) and horizontal (across municipalities) coordination and information sharing to ensure a coordinated approach to tackling air quality and ensuring maximum co-benefits e.g. for climate change. This should also include providing municipalities with clarity on legal powers and the basis by which they can take action to improve air quality. ï‚· Improve stakeholder awareness and engagement, including information campaigns, direct engagement and provision of air quality data (e.g. via air quality indices). This should include more collaborative engagement with NGOs and other relevant stakeholders who can support the development and implementation of policies and measures. Effective communication to the public and other relevant stakeholders is necessary to gain “buy-inâ€? to any new measures and the benefits they may bring. Financing For the two main sources of relevance for the cities considered within this report (i.e. domestic solid fuel burning and road transport), any additional measures to be taken will have implications for the general public as they require individuals to make changes – at a cost – to the way they travel, the 1 https://ec.europa.eu/environment/eir/index_en.htm 13 vehicle they drive and/or the way in which they heat their homes. Therefore, it is vital that sufficient funding for any new policies and measures (e.g. stove replacement programs) are identified and accessed ahead of implementation to ensure success. Potential funding sources are likely to include EU funds and/or national resources. They should be made available and distributed in an efficient and effective manner and allocated based on clear prioritization and eligibility criteria and capacity at a local level. Some of these funds could be allocated for a financial instruments scheme with preferential loans or loan guarantees being made available to eligible households. This could help to leverage additional funding from a range of other sources including private investors and international financial institutions. Income-based graduated grant schemes and related financial instruments should be considered to help support and protect low-income households that may be unable to pay e.g. for replacement of stoves. Fiscal incentives in the form of income tax credits or rebates/deductions for investments made in eligible stoves or vehicles, coupled with financial support mechanisms (such as partial grant financing) and financial instruments (such as preferential loans) should be considered to further incentivize uptake and replacement of stoves and vehicles. 14 Sustainable Cities Implementation Framework – Air Quality INTRODUCTION Air pollution is a global threat leading to significant impacts on human health and ecosystems, and currently represents the single, largest environmental health risk in Europe. In 2019, air pollution continued to drive a significant burden of premature death and disease in the 27 EU Member States: 307,000 premature deaths were attributed to chronic exposure to fine particulate matter, 40,400 premature deaths were attributed to chronic nitrogen dioxide exposure, and 16,800 premature deaths were attributed to acute ozone exposure2. Across Europe, people in larger cities tend to be exposed to higher levels of nitrogen dioxide due to emissions from road traffic. In central and eastern Europe, air quality remains poor in many areas, especially in urban settings, and the burning of solid fuels for domestic heating and in industry results in the highest concentrations of particulate matter (PM10 and PM2.5) and Polycyclic Aromatic Hydrocarbons (such as benzo(a)pyrene)3. The World Bank is developing a Sustainable Cities Implementation Framework for Europe and Central Asia to inform World Bank and other development partners’ ongoing support to national and sub-national authorities in pursuit of Sustainable Cities. As part of this work, preliminary assessments were conducted in four countries (Romania, Bulgaria, Poland and Croatia). As a result of these preliminary assessments, the need for deep dive analytics on three topics (Air Quality, Spatial Form and Solid Waste Management) was identified. The overall objective of this Deep Dive on Air Quality is to explore challenges in urban areas, focusing on existing data, identifying contributing factors to poor air quality, and providing recommendations (implementation support areas) to improve air quality. This Report focuses on four eastern European countries: Bulgaria, Croatia, Romania and Poland. An analysis of both pollutant emissions and concentrations has been carried out to identify trends in the data and compliance with the relevant air quality directives. These are then considered with regard to three key performance drivers: ï‚· Policy / legislation – policy or regulatory gaps, inconsistencies or overlaps that impede improvements to air quality; ï‚· Capacity / institutional – institutional arrangements, incentives and capacities, collaborations and partnerships; and ï‚· Financing – mismatches of functions and revenues at the city / regional scales, availability of funding / financing mechanisms to deliver air quality improvements, and misalignment of incentives to maximize funding / financing mechanisms. This Deep Dive assesses sources and data at both the national level and at the local level for the following cities: 2 European Environment Agency 2021. Health Impacts of Air Pollution in Europe. Briefing available at https://www.eea.europa.eu/publications/health-risks-of-air-pollution. 3 European Environment Agency 2021. Europe’s Air Quality Status 2021. Briefing available at: https://www.eea.europa.eu/publications/air-quality-status-2021. 15 Bulgaria: ï‚· Sofia, ï‚· Burgas, ï‚· Plovdiv, ï‚· Varna. Croatia: ï‚· Zagreb, ï‚· Split. Poland ï‚· Warsaw, ï‚· Katowice, and ï‚· Poznan. Romania ï‚· Bucharest, ï‚· Constanta, ï‚· Sibiu. The remainder of this Chapter provides general background on air quality issues insofar as they underpin why exposure to poor air quality in urban areas is so critical, and the importance to delivering Sustainable Cities. Key recommendations to improve air quality (both general and city-targeted) are then provided at the end of the Chapter. These are based on the findings set out in Chapters 2, 3, 4 and 5 which provide the detailed analyses for each of the four countries, related to trends in key pollutant emissions and concentrations, and the three key performance drivers. WHAT ARE THE POLLUTANTS OF CONCERN? The term “air pollutionâ€? covers a wide range of substances, all of which will be present in urban and industrial environments to varying degrees. It is therefore useful to focus down on substances which provide a broader indication of the level of air pollution, through their prevalence and association with observed health effects. This report mainly focuses on monitored and reported emissions and levels of nitrogen dioxide (NO2), particulate matter (measured as PM10 or PM2.5) and polycyclic aromatic hydrocarbons (PAH) as these are the main pollutants of relevance for urban areas. NO2 is both a primary and secondary pollutant. It is emitted directly in relatively small amounts from combustion sources, but is largely formed in the atmosphere from chemical reactions, principally between nitrogen oxides (NOx) and ozone (O3). The main sources of nitrogen dioxide in urban areas are road traffic and commercial / domestic heating. Ozone is predominantly a secondary pollutant formed by chemical reactions with other pollutants, principally NOx and non-methane hydrocarbons (NMHC). Due to the nature of the reactions, O3 concentrations tend to be lower close to the sources of the main precursors, such as busy roads in urban areas. Thus, NO2 is closely associated with a range of polluting sources and exceedances of the EU Limit Value for NO2 are the most widely reported by 16 Sustainable Cities Implementation Framework – Air Quality Member States. There is also a strong evidence base in relation to adverse health outcomes relating to elevated concentrations on NO2. Particulate matter is the most important contributor to human health effects. PM10 (particles less than 10 micrometers diameter) and PM2.5 (particles less than 2.5 micrometers diameter) are the most commonly used metrics. PM is a mixture of both primary and secondary components. Sources of primary particles include combustion processes such as diesel traffic, solid and liquid-fueled heating etc., but also includes mechanically-derived particles associated with tire and brake wear, and natural sources such as windblown dusts and sea salt. Secondary particles can include a wide range of components but are predominantly in the form of ammonium nitrate and ammonium sulphate; ammonia emissions from agricultural activities (originating from outside urban areas) play a key role in PM formation in cities. Secondary PM can travel long distances (known as transboundary pollutants) such that cities can be affected by pollution sources many hundreds of kilometers away. Once again, elevated concentrations of PM are associated with a range of emission sources, both direct and in terms of “precursorsâ€?, such as NO2, sulfur dioxide, volatile organic compounds, and ammonia. Its strong association with health effects makes PM the primary pollutant of concern in most circumstances (at least in relation to ambient air) and its transboundary nature, especially in relation to secondary PM, means that the control of PM is a European level issue. PAHs are a large group of compounds that typically exist as complex mixtures rather than as individual species. Benzo(a) pyrene (BaP) is considered to be one of the most toxic PAHs and so tends to be used as the “markerâ€? substance, but other PAHs have also been shown to be carcinogens. BaP is associated with poorly controlled combustion sources, and particularly solid fuel burning. In many Western European countries, PAH is not a major concern, being associated with a small number of industrial processes. However, in regions where solid fuel, and especially coal, provides the primary heating source for large parts of the population, levels of PAH can be a major concern. IMPACTS OF POOR AIR QUALITY Health Air pollution has a major impact on the sustainability of an urban area. It can negatively impact on the population and city in different ways, and it is a significant cause of premature death and morbidity, representing the single largest environmental health risk in Europe. Air pollution is a broad term that covers both gases and solid particles in the atmosphere. The main gaseous pollutants with a direct impact on human health are nitrogen dioxide (NO2) and ozone (O3), while particulate matter (PM) is described using a number of metrics. In Europe, heart disease and stroke are the most common reasons for premature deaths attributable to air pollution, followed by lung diseases and lung cancer .4 Poor air quality can also exacerbate other health conditions such as asthma, diabetes, allergies, and others5. The International 4 WHO. 2021. Ambient (outdoor) air pollution. https://www.who.int/news-room/fact-sheets/detail/ambient-(outdoor)-air- quality-and-health 5 EEA, 2020. Air pollution: how it affects our health? https://www.eea.europa.eu/themes/air/health-impacts-of-air-pollution 17 Agency for Research on Cancer (IARC) has classified air pollution in general, and diesel soot specifically, as carcinogenic.6 Furthermore, short- and long-term exposure to air pollution can reduce lung function and cause respiratory infections and aggravated asthma. Maternal exposure to ambient air pollution is associated with adverse impacts on fertility, pregnancy, newborns, and children. 7 There is also emerging evidence that exposure to air pollution is associated with new-onset Type-2 diabetes in adults.8 It may be linked to obesity, systemic inflammation, Alzheimer's disease, and dementia.9 Health Inequalities in Europe Environmental conditions are not the same everywhere, and disparities in exposure to environmental risks (including air pollution) occur both between and within Member States10. The uneven distribution of these risks and the related impacts on health and health equity are therefore of increasing concern, particularly within large urban areas where such inequalities can be greater. The uneven distribution of air pollution impacts on the health of European citizens reflects the socio- demographic differences across Member States. Individual characteristics, such as age or health, determine how susceptible people are to exposure to air pollution, while their ability to avoid or cope with this exposure is influenced by their socio-economic status. Older people, children, those experiencing material disadvantage and those in bad health, are more susceptible to air pollution. In many European countries, the disproportionate exposure of lower socio-economic groups to air pollution occurs in urban areas11, and so focusing interventions to susceptible populations in cities is critical. A more recent report investigated the links between exposure to air pollution, deprivation and ethnicity in London12. This concluded that communities which have high levels of deprivation, or a higher proportion of people from a non-white ethnic background, were more likely to be exposed to higher levels of air pollution, and that between 31 and 35 percent of areas with the highest proportion of black and mixed/multiple ethnicities are in areas with higher levels of air pollution, reducing to 15- 18 percent for Asian ethnic groups and just 4-5 percent for white ethnic groups. 6 IARC. 2013. WHO. IARC: Outdoor air pollution a leading environmental cause of cancer deaths. Press Release n. 221. https://www.iarc.who.int/wp-content/uploads/2018/07/pr221_E.pdf 7 Kim, Chen, et al. 2018 . Air pollutants and early origins of respiratory diseases. Chrisnic Dis Transl Med. 4(2): 75-74. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6033955/ 8 Dimakakou, Johnston, et al. 2018. Exposure to Environmental and Occupational Particulate Air Pollution as a Potential Contributor to Neurodegeneration and Diabetes: A Systematic Review of Epidemiological Research. Int J Environ Res Public Health. 15(8): 1704. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6121251/ 9 Hahad, Lelieveld, et al. 2020. Ambient Air Pollution Increases the Risk of Cerebrovascular and Neuropsychiatric Disorders through Induction of Inflammation and Oxidative Stress. Int. J. Mol. Sci. 2020, 21, 4306. C 10 World Heath Organization 2019. Environmental health inequalities in Europe. https://www.euro.who.int/en/publications/abstracts/environmental-health-inequalities-in-europe.-second-assessment- report-2019. 11 EEA, 2018. Unequal exposure and unequal impacts: social vulnerability to air pollution, noise and extreme temperatures in Europe. EEA Report 22/2018. Available at https://www.eea.europa.eu/publications/unequal-exposure-and-unequal- impacts. 12 Air Quality Consultants, 2021. Air pollution and inequalities in London: A 2019 Update. Available online https://www.london.gov.uk/sites/default/files/air_pollution_and_inequalities_in_london_2019_update_0.pdf. 18 Sustainable Cities Implementation Framework – Air Quality Links to Climate Change Air pollution and climate change are closely intertwined. Several air pollutants are also greenhouse gases (GHG), which potentially impact climate change and global warming in the short and long term. Tropospheric O3 and black carbon (BC) are examples of pollutants that are short-lived climate forcers and contribute directly to global warming. Other particular matter (PM) components, such as nitrates and sulphates have a cooling effect 13 . In addition, methane, which is a potent greenhouse gas, contributes to the formation of ground-level O3. Due to climate change, weather patterns may alter the transport, dispersion, deposition of air pollutants in urban environments, and higher temperatures will lead to increased O3 formation and greater heat stress, exacerbating health effects. As greenhouse gases and air pollutants share the same primary emission sources, potential benefits can arise from interventions that target these. Policies aimed at reducing air pollutants can reduce emissions of GHG, while climate policies aimed at reducing the combustion of fossil fuels or reducing BC and methane emissions mitigate air pollution damage to human health and the environment. Implementing integrated policies also avoids the potential negative impact of climate policies on air quality; examples include the negative impacts on air quality arising from promoting the uptake of diesel cars (which have lower carbon dioxide emissions but higher PM and NOx emissions) and the potential increase in PM emissions and emissions of other carcinogenic air pollutants associated with biomass burning in urban areas.14 Economic Impacts Because air quality can have many negative impacts on the health of urban populations, there are substantial costs associated with these impacts, with economic and social implications. The effects of air pollution on health, crop and forest yields, ecosystems, the climate, and the built environment also entail considerable market and non-market costs. The market costs of air pollution include reduced labor productivity, additional health expenditure, and crop and forest yield losses. Non-market prices are associated with increased mortality and morbidity, air and water quality degradation, and, consequently, ecosystem health and climate change. A recent study conducted by the European Public Health Alliance (EPHA)15 calculated that the cost of premature death, medical treatment, lost working days and other health costs caused by poor air quality in 432 cities across Europe amounts to €166 billion per year, or €385 million per city on average. One of the most notable take-aways from the study was the differences of health costs between major cities in central and eastern Europe compared to those from the west, where total annual costs and per capita have been dramatically higher. In many cities in Bulgaria, Romania, and Poland the social costs from poor air quality are relatively high, and between 8-10% of income earned per inhabitant, on average. 13 EEA, 2020. Report – Air Quality in Europe. https://www.europarl.europa.eu/meetdocs/2014_2019/plmrep/COMMITTEES/ENVI/DV/2021/01- 14/Air_quality_in_Europe-2020_report_EN.pdf 14 European Commission. 2010. Combined policies for better tackling of climate change and air pollution. Science for Environment Policy. Issue 24. https://ec.europa.eu/environment/integration/research/newsalert/pdf/24si_en.pdf 15 CE Delft. 2020. Health costs of air pollution in European citities and the linkage with transport. https://epha.org/wp- content/uploads/2020/10/final-health-costs-of-air-pollution-in-european-cities-and-the-linkage-with-transport.pdf 19 The Organization for Economic Co-operation and Development (OECD) estimated that a 1 μg/m3 decrease in annual mean PM2.5 concentration would increase Europe's gross domestic product (GDP) by 0.8 %, representing around €200 per capita per year (for 2017). Of this increase, 95% is the result of increased output per worker through lower absenteeism or increased labor productivity due to lower air pollution. This study concludes that more stringent air quality regulations could be warranted based solely on economic grounds. The direct economic benefits from air pollution control policies are more significant than the abatement costs, even when ignoring the large benefits of avoided mortality.16 The OECD further estimated that if all Member States met their national exposure reduction targets for PM2.5 in 2020, the European GDP would have grown by 1.28% between 2010-2020, accounting for the costs of the abatement of around 0.01 % of GDP. With the highest reduction target, Poland would increase its GDP by up to 2.9% and Bulgaria by 1.7%. The impact is around 1.5 % for other EU countries like Austria, Belgium, Czechia, France and Italy, and Germany.17 COVID-19 – IMPACTS ON AIR QUALITY The COVID-19 pandemic lockdowns had a pronounced effect across Europe, dramatically reducing traffic levels in major cities as the majority of people were required to stay at home and avoid travel. A report published by the European Environment Agency shows how concentrations of nitrogen dioxide, a pollutant most associated with road transport, fell sharply during the lockdown period in April 2020, ranging from a 61% reduction in Spain to a 20% reduction in the Czech Republic18. While concentrations of PM10 also fell across Europe in this period, the reductions were less pronounced; PM10 concentrations are influenced by a wider range of sources than nitrogen dioxide, including sources such as agriculture, industry and residential heating which are unlikely to have been affected by the lockdown measures. Whilst traffic levels across many European cities have now returned to their pre-lockdown levels, another study, commissioned by Transport & Environment, examined the potential for mobility policies to replicate the dramatic air quality improvements brought about by the COVID-19 lockdowns19. Air Quality Consultants used a sophisticated de-weathering model (boosted regression tree) to quantify the “realâ€? improvements between the most severe phase of lockdown in early 2020 and previous years for six cities – Berlin, Brussels, Budapest, London, Madrid and Paris. This revealed reductions in mean NO2 concentrations of between 3.2µg/m3 (Budapest) and 27.3 µg/m3 (Central London), with Paris showing the highest “city-averageâ€? improvement, at 20.6 µg/m3. The study also estimated the traffic contribution to measured pollution levels, based on a combination of air quality monitoring data and traffic data derived from emission inventories, to test how a series of scenarios 16 OECD. 2019.The economic cost of air pollution: Evidence from Europe, Economics Department Working Paper No 1584. http://www.oecd.org/officialdocuments/publicdisplaydocumentpdf/?cote=ECO/WKP(2019)54&docLanguage=En 17 OECD. 2019.The economic cost of air pollution: Evidence from Europe, Economics Department Working Paper No 1584. http://www.oecd.org/officialdocuments/publicdisplaydocumentpdf/?cote=ECO/WKP(2019)54&docLanguage=En 18 EEA, 2021. COVID-19 and Europe’s environment: impacts of a global pandemic. Available at https://www.eea.europa.eu/themes/air/air-quality-and-covid19. 19 Air Quality Consultants, 2020. Blue Sky Recovery: How Zero-Emission Vehicles and Reduced Car Use Can Allow Cities to Keep Lockdown-Low Levels of Air Pollution. Available at https://www.aqconsultants.co.uk/news/march-2021/blue-sky- recovery-how-zero-emission-vehicles-and. 20 Sustainable Cities Implementation Framework – Air Quality based on conversion of the vehicle fleet to zero exhaust emission alternatives, plus a combination of increased walking, cycling and home working, could produce the same effects. Two types of scenarios were investigated; two that relied on a switch to zero exhaust vehicles (ZEV) only, and three that looked at a combination of ZEVs with modal shift and demand reduction. The findings showed that, other than in Madrid and Paris, both types of scenarios could achieve reductions equivalent to lockdown levels; focusing on cars only, between 42% (Budapest) and 92% (London) of all car-km needed to be shifted to ZEVs. When using a combination of ZEVs with increased walking, cycling, public transport and reduced car use, the necessary shift to zero-emission cars could be achieved more rapidly, with a need to shift between 6% (Budapest) and 74% (London) of all car-km need to zero exhaust emissions. In two of the cities (Madrid and Paris), which had seen particularly strong reductions of traffic-related NOx emissions during lockdowns, only a mix of both strong modal shift and a switch to ZEVs more widely (including also vans and trucks) could deliver the targeted reductions. In Paris 67% of all vehicle-km needed to be switched to ZEVs. In Madrid, 10% of all km travelled by light and heavy-goods vehicles as well as 94% of car-km needed to convert to ZEVs. The two important considerations for this study were: ï‚· Mobility policies have the potential to substantially improve air quality in cities where road traffic is the predominant source of pollution; and ï‚· Pollution data measured during 2020 should be disregarded for the purpose of analyzing trends across European cities. EUROPEAN AND NATIONAL LEGISLATION AND FRAMEWORKS The overall air quality policy strategy of the EU is directed towards meeting the air quality guideline values of the World Health Organization (WHO) in the coming decades, as stated in the Seventh Environment Action Programme (7th EAP) of 2013. The 7th EAP captures the EU's 2050 vision of 'living well within the limits of the planet', recognizing the EU's long-term goal of achieving levels of air quality that do not give rise to significant negative impacts on, and risks to, human health and the environment. EU air pollution policy follows a twin-track approach: by setting legal limits for concentrations of air pollutants and by establishing agreements and standards to reduce emissions at source, i.e. national emission reduction commitments (total emissions) and sector-specific sources. Several policy packages have been released by the European Commission in recent years with the objective of ensuring full compliance with existing air quality standards across the EU as soon as possible. The 2013 Clean Air Programme for Europe (CAFÉ) included two legislative measures to help cut air pollution (a revised National Emission Ceilings Directive, containing emission reduction commitments for 2020 and 2030, and a directive to reduce pollution from medium-sized combustion installations), as well as focusing on improving air quality in cities, supporting research and innovation, and promoting international cooperation. Subsequently, the European Commission published its 2018 communication 'A Europe that protects: Clean air for all', describing the 'policy efforts of the EU to support and facilitate the necessary measures of the Member States to meet their targets, and the enforcement action being taken to help ensure that the common objective of clean air for all Europeans is achieved and maintained across the 21 EU'20. There are three main approaches adopted within the EU to reduce air emissions at source and to define minimum standards of air quality: 1. definition of ambient air quality standards; 2. setting of national emission reduction targets; and 3. setting of emission and product standards for key specific sources of air pollution. Ambient Air Quality Standards The Ambient Air Quality Directives (AAQDs)21,22 underpin air quality policy in Europe. Air quality standards (Limit and Target Values) for 12 key air pollutants, to be attained and maintained across the EU, are set in the AAQDs, requiring Member States to develop and introduce air quality plans for zones and agglomerations within which pollution levels exceed these standards, and to maintain the air quality in all other areas to protect human health and the environment. The Directive sets out the processes and procedures for checking compliance with the Limit and Target Values, based around ambient air quality monitoring using “referenceâ€? methods in zones and agglomerations. Member States are required to report the results of monitoring and other, supplementary assessments to show compliance with the Limit and Target Values in the previous year. This information is reported in a standard format to the European Environment Agency (EEA), acting on behalf of the European Commission, and is available through the EEA’s Central Data Repository (CDR)23. Member States are also required to inform the public about levels of air quality, including annual reports and when “information or alert thresholdsâ€? are breached. Most EU Member States now do this through websites which provide near-real time data, as well as access to archived data and reports. The AAQD is currently being revised by the European Commission24, to bring it into alignment with the European Green Deal’s ambition for a zero pollution Europe, and potentially with the revised WHO Air Quality Guidelines (described below). A draft of the revised Directive is currently expected in 2022. A summary of the air quality standards for the protection of human health is set out in Table 14 in the Appendix. In September 2021, the World Health Organization (WHO) published a revised set of guidelines for PM2.5, PM10, ozone (O3), NO2, sulphur dioxide (SO2) and carbon monoxide (CO)25. These update the previous guidelines issued in 2005 and are based on a review of evidence on the effects of air pollution on health, drawn from the last 16 years and more, by some of the world’s leading experts in the field. 20 EC, 2018. Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions ‘A Europe that protects: Clean Air for All’ (COM(2018) 330 Final) 21 EU, 2004. Directive 2004/107/EC of the European Parliament and of the Council of 15 December 2004 relating to arsenic, cadmium, mercury, nickel and polycyclic aromatic hydrocarbons in ambient air. 22 EU, 2008. Directive 2008/50/EC of the European Parliament and of the Council of 21 May 2008 on ambient air quality and cleaner air for Europe. 23 See: https://cdr.eionet.europa.eu/ 24 See: https://ec.europa.eu/environment/air/quality/revision_of_the_aaq_directives.htm 25 World Health Organization (2021). https://apps.who.int/iris/handle/10665/345329. 22 Sustainable Cities Implementation Framework – Air Quality In general, the Guidelines, shown in Error! Reference source not found. in the Appendix, have been made more stringent, other than for SO2, reflecting developments in health effects evidence which has demonstrated impacts at lower concentrations than previously. However, the shorter-term guidelines, including the 1-hour value for NO2 (200µg/m3), have been retained unchanged. Note that the guidelines are not legally binding but they “provide WHO Member States with an evidence- informed tool that they can use to inform legislation and policyâ€?. National Targets for Reducing Emissions In addition to the legislative framework on air quality standards, the revised National Emission reduction Commitments Directive (NECD) 26 sets 2020 and 2030 national emission reduction commitments (NERCs) for five main air pollutants — sulphur oxides (SOx), nitrogen oxides (NOx), non-methane volatile organic compounds (NMVOCs), ammonia (NH3) and primary fine particulate matter (PM2.5). Initially agreed in the Gothenburg Protocol, part of the Convention on Long-Range Transboundary Air Pollution (CLRTAP), NERCs are expressed in the NECD as a percentage reduction between a 2005 baseline and the target year which each Member State must comply with. The Directive also ensures that the emission ceilings for 2010 set in the previous 2001 NECD remain applicable for Member States until the end of 2019. Additionally, the NECD establishes a NERC for the EU as a whole, to be achieved from 2030 onwards. The new NECD introduced a requirement for EU Member States to develop National Air Pollution Control Programmes (NAPCPs) by 2019, with a subsequent Implementing Decision27 specifying the format and content requirements. Under this format, Member States are required to identify considered and subsequently adopted Policies and Measures (PaMs). Furthermore, the Directive seeks to enhance synergies between air quality and other policy areas, chiefly climate and energy, to deliver co-benefits. To this end, Member States are required to assess and report on the coherence of adopted PaMs with other policy instruments and areas, and NAPCPs should contribute to the implementation of air quality plans established under the AAQD. Emissions reduction commitments specified in the NECD for Bulgaria, Croatia, Poland and Romania, expressed as percentage reductions compared to 2005 emissions, are displayed in Table 1. The European Commission conducted a review of progress made in implementing the NECD in 202028. This included an assessment of the risk of Member States failing to comply with their targets based on their NAPCPs and accompanying emissions projections. The risks of non-compliance determined through the review (based on reported projected compliance, the strengths of the NAPCPs and emission projections including additional policies and measures to be implemented) are also presented in Table 1. No assessment was completed for Romania as no NAPCP has been submitted to date. 26 EU. 2016. Directive 2016/2284/EC of the European Parliament and of the Council 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. 27 EU. 2018. 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. 28 European Commission. 2020. Annexes to the Report from the Commission to the European Parliament and the Council on the progress made on the implementation of Directive (EU) 2016/2284 on the reduction of national emissions of certain atmospheric pollutants. 23 Table 1: National emissions reduction commitments for Bulgaria, Croatia, Poland and Romania Commitment Bulgaria Croatia Poland Romania Sulphur dioxide (SO2) 2020-2029 78% 55% 59% 77% Risk of non- Medium Low High - compliance 2030 onward 88% 83% 70% 88% Risk of non- Low Low High - compliance Nitrogen oxides (NOx) 2020-2029 41% 31% 30% 45% Risk of non- High Low High - compliance 2030 onward 58% 57% 39% 60% Risk of non- High Low High - compliance Non-methane volatile organic compounds (NMVOC) 2020-2029 21% 34% 25% 25% Risk of non- High Medium High - compliance 2030 onward 42% 48% 26% 45% Risk of non- High Medium High - compliance Ammonia (NH3) 2020-2029 3% 1% 1% 13% Risk of non- High Medium High - compliance 2030 onward 12% 25% 17% 25% Risk of non- High Medium High - compliance Particulate matter (PM2.5) 2020-2029 20% 18% 16% 28% Risk of non- Low Medium Medium - compliance 2030 onward 41% 55% 58% 58% Risk of non- Low Medium High - compliance Emissions and Product Standards for Key Pollution Sources Sector-specific legislation is used in the EU for establishing standards, such as emission limit values or quality standards, for important sources. The areas addressed include: ï‚· industrial emissions; ï‚· road and non-road vehicles; ï‚· fuels; and ï‚· product design standards for certain equipment such as domestic stoves, implemented through, for example, the Eco-design Directive. 24 Sustainable Cities Implementation Framework – Air Quality Industrial Emissions The Industrial Emissions Directive (IED)29 was adopted on 24 November 2010. In addition to revising the Integrated Pollution Prevention and Control (IPPC) Directive, it also incorporated a number of other Directives related to VOCs, waste incineration, and large combustion plants. The principal intent of the IED is “to prevent or, where that is not practicable, to reduce emissions into air, water and land and to prevent the generation of waste, in order to achieve a high level of protection of the environment taken as a wholeâ€?. The concept of Best Available Techniques (BAT) is used to set permit conditions and emissions limits that may not be exceeded. These are based on BAT Conclusions adopted following the development or revision of a BAT Reference (BREF) document for a particular activity. The Medium Combustion Plant Directive (MCPD)30entered into force on 18 December 2015, and limits emissions from Medium Combustion Plant (defined as plant with a rated thermal input of between 1 and 50 MW). Emission Limit Values (ELVs) are defined for sulphur dioxide, nitrogen oxides and dust, with different ELVs applied depending on whether the plant is fueled by solid biomass, other solid fuels, gas oil, other liquid fuels, natural gas or other gaseous fuels. Road Vehicles Emissions from both light duty (passenger and commercial) vehicles and heavy duty (lorries and buses) vehicles are controlled under a series of EU regulations. For light duty vehicles these relate to the Euro 1 to Euro 6 standards, while for heavy duty vehicles these relate to the Euro I to Euro VI standards. The emissions standard for Euro 6 diesel vehicles is being delivered in three stages, commonly referred to as Euro 6a/b, 6c and 6d. An important component of type approval is the requirement to verify on-road emissions performance, known as Real Driving Emissions (RDE), which requires the use of Portable Emissions Monitoring Systems (PEMS). The Technical Committee on Motor Vehicles agreed a package of RDE test procedures on 28 October 2015, which has since been agreed by the European Parliament, and which imposes a staged reduction in Conformity Factors for NOx emissions through to Euro 6d vehicles31. Emissions from Euro VI heavy-duty vehicles are governed by Regulation 595/2009. The emissions standards applied from 31 December 2012 (for new types of engines) and 31 December 2013 (for new registrations), and testing is based on the World Harmonized Steady State Cycle (WHSC) and the World Harmonized Transient Driving Cycle (WHTC). Fuels 29 EU. 2010. Directive 2010/75/EU of the European Parliament and of the Council of 24 November 2010 on industrial emissions (integrated pollution prevention and control) 30 Directive (EU) 2015/2193 of the European Parliament and of the Council of 25 November 2015 on the limitation of emissions of certain pollutants into the air from medium combustion plants 31 The performance of vehicle emissions with regard to the Euro standard for LDVs is referred to as the Conformity Factor (CF). For Euro 6 diesel vehicles, this is being delivered in stages. A CF of 2.1 will apply from 2017 to 2020 (Euro 6c) and thereafter a CF of 1.5 (Euro 6d). 25 The Fuel Quality Directive was adopted on 13 October 199832 and has subsequently been amended numerous times, with the most recent amendments made on 11 December 201833. Applicable to petrol, diesel and biofuels used in road transport, as well as gasoil used in non-road mobile machinery (NRMM), the Directive required a 6% reduction of the greenhouse gas intensity of transport fuels by 2020. Member States are required to ensure that fuel suppliers comply with this target after 2020. In addition, the Directive has implications for air quality by setting fuel content requirements, including limiting petrol and diesel sulphur content to 10 mg/kg. Product design standards The Eco-design Directive34, adopted on 21 October 2009, sets a framework for the establishment of product-specific requirements with regard to energy efficiency or environmental performance. A variety of different product types are included within the scope of the Directive, including household appliances such as cookers, and heating and cooling appliances, including solid fuel boilers. Product- specific requirements are defined through subsequent regulations. Among these, Commission Regulation 2015/1189 35 sets requirements for solid fuel boilers, including maximum emissions of particulate matter, organic gaseous compounds, carbon monoxide and nitrogen oxides. IMPORTANCE OF GOOD AIR QUALITY FOR SUSTAINABLE CITIES – CHALLENGES FOR DELIVERY Air quality plays an important role in the sustainability of urban environments and affects multiple levels of society in differing ways. The AAQDs described above require Member States to take appropriate measures to ensure compliance with the limit and target values within the specified deadlines, and/or to maintain compliance once these have been met. As such, Member States are required to develop air quality plans in zones and agglomerations where there is a risk of exceedances of the limit / target values. The AAQDs leave the choice of the means of achieving the limit / target values to individual Member States. In many Member States, responsibility for developing and implementing these air quality plans has been devolved by national governments to local governments, principally at the city scale. However, as explored in the following section, there are often many challenges to local governments’ ability to deliver the required outcomes. Because urban areas have higher concentrations of most pollutants, and a growing proportion of Europe’s population live in urban settings (75% in 2018)36, there is a strong justification to focus the development of interventions to address air quality within cities. As many European cities continue to grow in size, and an increasing number of people are potentially exposed to higher levels of air 32 EU. 1998. Directive 98/70/EC of the European Parliament and of the Council of 13 October 1998 relating to the quality of petrol and diesel fuels and amending Council Directive 93/12/EEC. 33 EU, 2018. Regulation (EU) 2018/1999 of the European Parliament and of the Council of 11 December 2018 on the governance of the Energy Union and climate action. 34 EU. 2009. Directive 2009/125/EC of the European Parliament and of the Council of 21 October 2009 establishing a framework for the setting of eco-design requirements for energy-related products. 35 EU. 2015. Commission Regulation (EU) 2015/1189 of 28 April 2015 implementing Directive 2009/125/EC of the European Parliament and of the Council with regard to eco-design requirements for solid fuel boilers. 36 World Bank. 2018. Urban Population (% of total population). https://data.worldbank.org/indicator/SP.URB.TOTL.IN.ZS?end=2020&start=1960 26 Sustainable Cities Implementation Framework – Air Quality pollution, so there is an increasing urgency to implement coordinated and integrated policy, strategies and deploy investments at the city level to achieve better air quality. National-regional-local governance structures vary considerably between countries, as do the powers and responsibilities devolved to the city scale. In broad terms, the role of city authorities in delivering improved air quality can be summarized as: ï‚· Development of an evidence base to describe the spatial and temporal variation in air pollution at the local scale, i.e. identification of hotspots and local activity giving rise to such hotspots. For example, Warsaw is setting up a network of 165 small air quality sensors37 which will not provide compliance data to the standards required by EU Directive but will allow a more detailed understanding of how air pollution varies across the Polish Capital. This means that any interventions can be targeted to the areas of greatest need. ï‚· Shape the implementation of interventions to suit local circumstances. The nature of such interventions will depend on the powers and responsibilities devolved to the city but could include establishing intervention areas (e.g. Low Emission Zones) or setting development parameters to “build outâ€? problems. ï‚· The development of infrastructure which facilitates the uptake of low emission technologies and lifestyles, for example, walking, cycling (through the provision of dedicated cycle paths) or the uptake of low emission vehicles (through the provision of public access vehicle charging points). ï‚· Raising awareness of air pollution and its impacts, and co-opting voluntary measures both from the general public and from local employers and institutions. These “softâ€? measures could include workplace travel plans or driver training programs. City authorities can also have a major impact through “greenâ€? procurement programs which can both reduce its own impact and support the development of green services, such as electric vehicle service and maintenance. There are, however, challenges to delivering these goals which are important to the performance drivers and implementation support areas that are considered in this Report. A study published by the European Environment Agency38 explored the challenges in addressing air pollution problems in European cities over a five-year period (2013-2018). The study focused on 10 cities (Antwerp, Berlin, Dublin, Madrid, Malmo, Milan, Paris, Plovdiv, Prague and Vienna), and evaluated challenges with regard to the implementation of air quality legislation at the urban scale. The main challenges identified by city representatives were legal or financial aspects, or those arising from public opposition, and are summarized below. ï‚· Administrative competences: these related to issues of administrative competences across different governance levels and to collaboration between local, regional and national authorities. There were challenges in implementing proactive measures at the city level where national governments had a lower ambition. The perceived failure of EU and Member State policies was also flagged e.g. the failure of light-duty vehicle type approval tests in reducing real-world emissions of NOx, which hampered other initiatives at the city level to deliver reductions in concentrations of nitrogen dioxide. Collaboration between 37 See: https://airly.org/en/warsaw-is-the-european-capital-with-the-largest-air-quality-monitoring-network/?s=09 38 EEA, 2019. Europe’s urban air quality – reassessing implementation challenges in cities. ISSN 1977-8449. 27 administrations was also seen as key, and specifically related to emissions arising from outside of city areas, including sources such as agriculture and industry, and long-range transboundary transport of ozone and secondary aerosols. ï‚· Financial mechanisms: access to financial and fiscal measures to support citizen incentives or subsidies was considered key to driving the uptake of cleaner technologies at the city scale e.g. related to cleaner vehicles and domestic heating appliances. ï‚· Public acceptance: related to challenges in awareness raising and in overcoming objections to specific mitigation measures. ï‚· Technological challenges: several cities raised issues regarding the availability of the correct tools (such as dispersion models) to assess air quality at the city scale, also taking into account localized hotspots. ï‚· Political stability / support: changes in government (and specifically at the local level) can lead to the withdrawal or delay in the implementation of mitigation strategies that has previously been approved. In contrast, strong political support has a positive effect in public awareness raising. ï‚· Policy enforcement: several cities highlighted issues with regard to challenges in enforcing low-emission zones. Areas for which further action and guidance was highlighted included: ï‚· Information to the public and public engagement: the main request for guidance related to communicating information to the public. Opportunities to work with external specialist support, and sharing best practices with other cities were all considered important. ï‚· Modelling and Emission Inventories: all cities highlighted the need for guidance on how to collate robust information to estimate the impacts of mitigation measures, and specifically within the road transport sector where there are many uncertainties. ï‚· Other issues and topics: a variety of other issues related to guidance and capacity building were identified. This included guidance on the use of cost-benefit analysis tools (emissions, modelling, health impact assessment), public communication tools (including use of citizen science), and best approaches to coordinate with other environmental impacts such as climate change, noise, health and wellbeing. The need for better collaboration across different administrative levels was highlighted as an area for improvement, together with improved definition of responsibilities at the city level and access to external, expert advice. EU regulation was sometimes perceived as hindering local initiatives through bureaucracy (competition rules, public procurement rules) which delayed the implementation of measures in cities. The value of better coordination and sharing of best practices was highlighted by many cities, as the knowledge and experiences gained by leading cities are not readily available to others. In conclusion, the EEA report identified a clear need for streamlining and the provision of guidance on processes and practices in the application of interventions at the city scale. There is a requirement for better and regular exchange of information related to knowledge, experiences, good practice and capacity building. 28 Sustainable Cities Implementation Framework – Air Quality RECOMMENDATIONS Tackling air pollution successfully requires a mix of policies and investments, including complementary ‘sticks and carrots’. No single approach will be able to reduce air pollution from all sources. Air quality management is complex and requires national, regional and local level actors to be working in harmony. A good starting point is to ensure that each of these structures has the resources, knowledge, and incentive to engage and take action, and is subsequently held accountable against measurable outcomes. This section identifies a series of recommendation to address the key urban air quality challenges in the countries of interest. These are summarized against the following three main areas: policy and legislation, institutions and capacity, and finance. Country-specific recommendations are included in each country chapter. POLICY AND LEGISLATION There is a broad body of EU legislation covering air quality and emissions – including source specific regulations – which has been transposed into national legislation. This provides an effective framework for managing and improving air quality. However, there appear to be some gaps in relation to compliance with this legislation (e.g. exceedances of EU air quality standards) primarily due to limitations in the development and implementation of additional local, regional and national policies and measures to supplement and support EU policy. For example, in a number of cities in the countries considered in this deep dive, the limit values for NO2 and PM10 are exceeded due to road transport and domestic sources, and the target values for PAH are exceeded due to solid fuel use in domestic heating and energy generation. Whilst EU policy provides some contribution to reducing emissions from these sources (e.g. EURO vehicle emission standards for new vehicles), further local (and/or national) measures are required in order to further reduce emissions. For domestic sources, there are a number of possible policies and measures that could be considered, including the following: ï‚· Banning the burning of all solid fuels in domestic properties (or poor-quality solid fuels as part of a phase out); this could be implemented via a ban on the sale of such fuels to domestic customers. ï‚· Grants and/or other incentives to support the replacement of solid fuel boilers / stoves with gas or electric boilers / stoves or implementation of district heating schemes, focusing initially on older stoves and boilers that do not meet the European Eco-design standards. For road transport, there are a number of additional measures that could be considered, including the following: ï‚· Policies and measures to increase the uptake of low emission and electric vehicles, such as: o Scrappage schemes to incentivize phase-out of the older, more polluting vehicles. o Low emission / clean air zones restricting all, or the most polluting vehicles, from air quality hotspots. o Grants and/or other incentives (e.g. differential taxation) to incentivize the purchase of low emission or fully electric vehicles. 29 o Investments in the necessary infrastructure to support switching to electric vehicles (e.g. charging infrastructure) ï‚· Policies and measures to reduce vehicle activity, such as: o Improvements to public transport systems. o Improved cycling and walking infrastructure. o Communication and education schemes. For both road transport and domestic sources, a number of the policies and measures described above could be considered in combination, for example the introduction of a low emission zone combined with financial incentives to support the purchase of low emission vehicles. European legislation also requires minimum standards in terms of the quality and quantity of air quality monitoring. Concerns have been raised, by the European Commission and others, that these minimum standards are not being met in some of the countries considered in this deep dive. However, a greater range of evidence support tools are required to develop and successfully direct interventions to improve air quality, to ensure they are targeted at the areas of greatest need. While there is some evidence that these tools are being supported, such as a forthcoming small sensor network in Warsaw, greater assistance will be needed to ensure that the required monitoring, modelling and emissions assessment tools are available at the city scale. Finally, there appear to be some governance issues between local, regional and national authorities hindering the development and uptake of the additional measures required to improve air quality. These are discussed further below. INSTITUTIONS AND CAPACITIES In order to effectively develop and implement air quality policy, it is important that national, regional and local authorities can deliver on their own tasks and work effectively with each other within a multi-level governance system. Whilst there is already a well-developed policy framework in place (albeit with a need for further local, regional and/or national actions), there are a number of challenges in relation to institutional capacity and governance . The European Commission’s Environmental Implementation Review (EIR)39 has identified – for some of the countries considered in this report – major governance issues linked to government effectiveness and regulatory quality. Issues related to rule of law and control of corruption have also been identified in some of the countries. Furthermore, limited resources within local municipalities can impact on their ability to develop and implement effective policies and take actions to improve air quality. Finally, challenges with information sharing and co-ordination (between government bodies at all levels and with other stakeholders) have been identified. Each of these challenges – individually and collectively – can hinder the effective and efficient development and implementation of robust air quality (and other) policies. Potential recommendations to address some of the challenges include the following: ï‚· Increased human and financial resources at the municipality level to ensure they can prepare and implement effective air quality action plans and measures. Increased resources can also 39 https://ec.europa.eu/environment/eir/index_en.htm 30 Sustainable Cities Implementation Framework – Air Quality support municipalities with accessing wider funding sources due to the complexity and resources required for applications e.g. for European structural funds. ï‚· Sharing of resources between municipalities including access to relevant tools (e.g. for air quality modelling and emission inventories). This could include the establishment of centralized shared toolkits, materials and/or training materials. ï‚· Capacity building support to improve technical capabilities for air quality assessment and management e.g. for modelling and emissions inventories, designing new policies. ï‚· Improve vertical (between different levels of government) and horizontal (across municipalities) coordination and information sharing to ensure a coordinated approach to tackling air quality and ensuring maximum co-benefits e.g. for climate change. This should also include providing municipalities with clarity on legal powers and the basis by which they can take action to improve air quality. ï‚· Improve stakeholder awareness and engagement, including information campaigns, direct engagement and provision of air quality data (e.g. via air quality indices). This should include more collaborative engagement with NGOs and other relevant stakeholders who can support the development and implementation of policies and measures. Effective communication to the public and other relevant stakeholders is necessary to gain “buy-inâ€? to any new measures and the benefits they may bring. FINANCING For the two main sources of relevance for the cities considered within this report (i.e. domestic solid fuel burning and road transport), any additional measures to be taken will have implications for the general public as they require individuals to make changes – at a cost – to the way they travel, the vehicle they drive and/or the way in which they heat their homes. Therefore, it is vital that sufficient funding for any new policies and measures (e.g. stove replacement programs) are identified and accessed ahead of implementation to ensure success. Potential funding sources are likely to include EU funds and/or national resources. Financial support should be made available and distributed in an efficient and effective manner and allocated based on clear prioritization and eligibility criteria and capacity at a local level. Some of these funds could be allocated for a financial instruments scheme with preferential loans or loan guarantees being made available to eligible households. This could help to leverage additional funding from a range of other sources including private investors and international financial institutions. Income-based graduated grant schemes and related financial instruments should be considered to help support and protect low-income households that may be unable to pay e.g. for replacement of stoves. Fiscal incentives in the form of income tax credits or rebates/deductions for investments made in eligible stoves or vehicles, coupled with financial support mechanisms (such as partial grant financing) and financial instruments (such as preferential loans) should be considered to further incentivize uptake and replacement of stoves and vehicles. 31 BULGARIA URBAN CONTEXT BASIC DEMOGRAPHIC AND SPATIAL INDICATORS40 POPULATION SPACE Population: 6 927 290 inhabitants (2020) Area: 111,000 km2 Urban Population: 73% Settlement area: 623.4 m2 / capita 41 Pop. in Urban Agglomeration > 1 mil. (% total): 18% Population Density: 64 inhabitants / km2 Population Change: -3.8% (2012-2018), -5,1% by Built-up Area Change: 28% (2012-2018) 2020 Population Growth Rate: -0.64% (2012-2018) Land Consumption Rate: 4.1% (2012-2018) EEA CITY AIR QUALITY RANKING ON THE LEVEL OF PM2.5 MEAN CONCENTRATIONS OVER 2019 & 202042,43 CITY BURGAS PLOVDIV SOFIA VARNA EU ranking No data 292/323 No data 259/323 Fine particulate matter (PM2.5) No data 19.0 No data 16.2 in μg/m3 City’s 335,818 population 202,766 (2.9%) 337,900 (4.9%) 1,201,209 (17.3%) (4.9%) (National %) This chapter examines the air quality situation in Bulgaria, with a particular focus on four urban settings: Burgas, Plovdiv, Sofia, and Varna. It examines the key sources and trends in emissions of air pollutants and resulting air quality. Furthermore, it analyzes the current status, challenges and gaps in air quality management focused on the following three areas: Policy & Legislation, Institutions & Capacity, and Financing. Finally, recommendations for further improving air quality are presented. EMISSION TRENDS Emissions data for 1990 and 2019 submitted by Bulgaria under the NECD are displayed in Table 2. Over this period, significant reductions in emissions of ammonia, NMVOC, NOx and SO2 were observed. By contrast, PM2.5 emissions have increased by almost a third in the same timeframe. 40 Data source: World Bank Data (population and geography), Eurostat (land consumption) 41 EU-27 average: 703.4 m2 / capita 42 EEA. 2021. “European city air quality viewer.â€? https://www.eea.europa.eu/themes/air/urban-air-quality/european-city- air-quality-viewer 43 Cities marked as “No dataâ€? have not been included in the EEA “European city air quality viewerâ€? for one of the three reasons below: ï‚· The city does not have urban or suburban air quality monitoring stations. ï‚· The urban and/or suburban air quality monitoring stations in the city have not reported data covering 75% of the days in the year. ï‚· The city is not included in the database of cities established under the European Commission’s Urban Audit. 32 Sustainable Cities Implementation Framework – Air Quality Table 2: Total pollutant emissions for Bulgaria, 1990-201944 Pollutant Emissions (kt) 1990 2019 Reduction NH3 204 85 59% NMVOC 890 156 82% NOx 548 184 66% PM2.5 46 60 32% increase SO2 2,211 148 93% Data from the EEA’s 2021 country fact sheet for Bulgaria 45 (displayed in Figure 1 and Figure 2) indicate that total emissions of SO2 have declined sharply since 2011, with a more gradual decline in NMVOC and NOx emissions over the same period of time. Emissions of NH3, PM2.5 and SO2 have remained largely stable since 2010. The main sources of NOx emissions are road transport, energy production and agriculture, with the contribution from energy production reducing markedly since 2011. The dominant source of PM2.5 emissions since 2010 has been residential, commercial and institutional energy consumption. The significant decline in SO2 emissions has been driven principally by reductions in energy production emissions, which continue to be the primary source of SO2 in 2019. Ammonia emissions have been consistently dominated by agricultural emissions since 2010. Emissions of NMVOC arise from a mix of sources with large contributions from the residential (26% in 2019) and light industry (28% in 2019) sectors. Note: figures are displayed with divisions within sectors to represent unlabeled sub-sectors; for example, transport is divided into road and non-road transport. 44 EEA. 2021. National Emission reductions Commitments (NEC) Directive emission inventory data. https://www.eea.europa.eu/data-and-maps/data/national-emission-ceilings-nec-directive-inventory-18 45 EEA. 2019. Bulgaria – Air pollution country fact sheet. https://www.eea.europa.eu/themes/air/country-fact-sheets/2021- country-fact-sheets/bulgaria 33 Figure 1: Total NOx emissions timeseries by sector for Bulgaria Figure 2: Total PM2.5 emissions timeseries by sector for Bulgaria TRENDS BY KEY SOURCE SECTOR ENERGY INDUSTRIES Data from the International Energy Agency (IEA) (Figure 3) indicate that in 2019, Bulgaria’s energy supply was comprised primarily from fossil fuels, with coal, oil and natural gas accounting for 27%, 24% and 13% of supply respectively. Between 1990 and 2000, there has been an overall reduction in total energy supply. Since 2000, coal and oil use have remained stable, while natural gas use has decreased. Fossil fuels continue to dominate the energy mix in 2019. 34 Sustainable Cities Implementation Framework – Air Quality Figure 3: Total energy supply in Bulgaria by energy source, 1990-201946 Transport Road transport is the biggest consumer of fuel within the transport sector in Bulgaria; in 2016, road transport consumed 95% of all transport fuel47. Between 1990 and 2019, the number of registered passenger cars in Bulgaria increased from over 1.3 million to almost 3.2 million47. Simultaneously, the number of HDVs and LDVs has more than doubled from 228,000 to 484,000, and the number of buses has risen from 7,500 to 21,300. This rise in registered vehicles has been accompanied by increased car usage, with car trips representing almost 80% of total passenger-kilometers travelled in 201548. It has also resulted in increased congestion; average time spent in congestion has increased from 30.4 hours in 2014 to 31.9 hours in 2016. Sofia is the 24th most congested large city49 in Europe, with a congestion level of 29%48. Use of buses in Bulgaria (17.5%) is higher than the EU-28 average (9.4%), although rail use (2.2%) is much lower (7.6%). Emissions from road transport are exacerbated by Bulgaria’s comparatively old traffic fleet; in 2019 approximately 67% of registered vehicles were over 15 years old, and 39% were over 20 years old47. Figure 4 indicates that fuel consumption by road transport has nearly tripled between 1990 and 2019, which is consistent with the increase in registered vehicle numbers. Prior to 1995, the road transport fuel mix consisted almost exclusively of petrol (gasoline) and smaller amounts of diesel. Petrol consumption has gradually declined, while diesel consumption has increased substantially to form the major share of fuel consumed in 2019. Liquefied petroleum gas (LPG), biomass and gaseous fuels form minor contributions to overall consumption. 46 IEA. 2019. Country profile: Bulgaria. https://www.iea.org/countries/bulgaria 47 Republic of Bulgaria Ministry of Environment and Water. 2021. Bulgaria’s Informative Inventory Report 2021 (IIR). 48 EC. 2019. The Environmental Implementation Review 2019: Country Report – Bulgaria. 49 Defined as any city with a population of over 800,000. 35 Figure 4: Road transport fuel consumption in Bulgaria by fuel type, 1988-201947 Uptake of alternative and ‘clean’ fuels in new passenger cars sold in Bulgaria is among the lowest in Europe. In 2017, Bulgaria had the second lowest number of electric vehicle charging points in the EU- 2850 at 1.7 charging points per 100,000 inhabitants in peri-urban areas; a total of only 22 publicly accessible charging points in the country. Similarly, there were only 0.8 charging points per 100 km of road in 202051. Details on road transport in Sofia are set out in Box 1. Box 1: Road transport in Sofia52 Road transport is a major contributor to air pollution in the Sofia Municipality. Diesel vehicles make up 41% of passenger cars. The average car age in the jurisdiction is 16 years, and the majority of vehicles do not meet the Euro 4 standard. Uptake of full electric cars is low, with the combined share of electric, hybrid, LPG and CNG cars at 5%, although this figure is increasing. The Sofia Municipality has an extensive public transport network in place, and numerous initiatives are underway to improve use of public transport. These include additional investment, awareness campaigns and the construction of a third metro line, with further extensions planned. The “Vision for Sofiaâ€? study identified the need for greater alignment between the metro system and other public transport services. Cycling infrastructure in Sofia is limited, with only 4km of cycle paths per 100,000 population. Poor integration of cycle routes has inhibited uptake of cycling in the city, with cycling currently constituting only a 2% mode share. OTHER FUEL COMBUSTION SOURCES (INCLUDING RESIDENTIAL) Residential fuel use, including domestic heating, is a major source of emissions of PM10 and NOx in urban areas. Data from Bulgaria’s IIR47 indicates that total fuel consumption in the residential sector 50 EU-27 plus the UK. 51 ACEA. 2021. Electric cars: 10 EU countries to not have a single charging point per 100km of road. https://www.acea.auto/press-release/electric-cars-10-eu-countries-do-not-have-a-single-charging-point-per-100km-of- road/ 52 EBRD. 2020. The Green City Action Plan: Sofia, Bulgaria. https://ebrdgreencities.com/assets/Uploads/PDF/7181e1a1c8/Sofia-GCAP_ENG.pdf 36 Sustainable Cities Implementation Framework – Air Quality has been variable between 1990 and 2019. Use of liquified fuels largely ceased as of 1997, with biomass increasing over the period to constitute the major share of fuel consumption in 2019. Solid fuel use has steadily declined. Figure 5: Residential fuel consumption in Bulgaria by fuel type, 1990-201947 Box 2: Residential emissions in Sofia Error! Bookmark not defined. Domestic heating has been identified as one of the main sources of PM10 emissions, specifically from low-quality solid fuels and wood with high moisture content. Two Ordinances have been adopted, setting out quality requirements for coal and wood used in domestic heating respectively. Waste materials are also used as fuel in domestic heating to an extent. The Sofia Municipality is served by a natural gas-powered district heating network. The coverage of the network is continuously expanding through a pipe infrastructure renewal programme, but district heating costs are prohibitive to some residents. As such, use of solid fuels has persisted, and the EU has funded a programme to facilitate transition from solid fuels to cleaner alternatives. AIR QUALITY TRENDS Bulgaria is one of the EU Member States with the poorest air quality in urban areas, with high levels of urban population exposure to particulate matter resulting in significant pollution-related deaths and years of life lost. According to the EEA, air pollution was responsible for over 10,000 premature deaths in Bulgaria in 201953. Although the country has recently adopted amendments to its legislation, Bulgaria has not yet taken structural measures to address air pollution and to align air quality objectives with specific key sectoral policies (e.g. climate, transport, energy).54 53 EEA. 2021. Air Quality in Europe 2021: Table 3. Premature deaths attributable to PM2.5, NO2 and O3 exposure in 41 European countries, 2019. https://www.eea.europa.eu/publications/air-quality-in-europe-2021/table-4/#table-3- premature-deaths-attributable-to-pm2-5-no2-and-o3-exposu 54 EC. 2019. “The Environmental Implementation Review. Country Report. Bulgaria.â€? https://ec.europa.eu/environment/eir/pdf/report_bg_en.pdf 37 The EEA has produced maps and graphs illustrating air quality in 2019 in Bulgaria45; these are displayed in Figure 6, Figure 7 and Figure 8. The maps on the left display air quality monitoring stations and the concentrations of pollutant monitoring at each station. The graphs on the right present trends in annual mean concentrations since 2010 by station type. For PM10 measurements, the 90.41 percentile of annual measurements is presented, which is used to approximate compliance with the daily limit value. The maps indicate exceedance of the daily mean limit value for PM10 in 2019, at urban and suburban monitoring locations, including those in Plovdiv and Sofia. Concentrations at locations in Varna and Burgas are compliant with the limit value. Concentrations of NO2 were compliant with the annual mean limit value at all locations displayed, with the exception of an urban traffic monitoring site in Sofia. The annual mean target value for BaP has been exceeded at measurement locations to the north, south and west of the country whilst levels in Varna and Burgas were compliant with the target. The graphs indicate that following a spike in 2011, PM10 and BaP concentrations have generally been declining between 2010 and 2019. There are no discernible trends in NO2 concentrations over the same period. Figure 6: PM10 measurement data and measurement locations in Bulgaria 38 Sustainable Cities Implementation Framework – Air Quality Figure 7: NO2 measurement data and measurement locations in Bulgaria Figure 8: BaP measurement data and measurement locations in Bulgaria For the purpose of air quality assessment in line with the Ambient Air Quality Directive, Bulgaria is divided into three agglomerations (Capital Agglomeration, Plovdiv, and Varna) and three zones (North- Danube, South West, and South East)55. Bulgaria has twice been referred to the Court of Justice of the European Union for continued exceedances of the annual and daily mean limit values for PM10 (in June 2015 56 and December 2020 57 ), with as many as 90 days per year above the daily limit. The second referral notes that 55 EC. 2014. Atlas of air quality zones and monitoring stations (2013 & 2014): Bulgaria. https://ec.europa.eu/environment/air/pdf/quality_by_country/BG_AirQualityZones_Current_opt.pdf 56 EC. 2015. Commission refers BELGIUM and BULGARIA to Court and gives Sweden a final warning over poor air quality. https://ec.europa.eu/commission/presscorner/detail/EN/IP_15_5197 57 EC. 2020. Air quality: Commission decides to refer BULGARIA to the Court of Justice over its failure to comply with previous judgement, https://ec.europa.eu/commission/presscorner/detail/EN/IP_20_2150 39 following the initial referral, Bulgaria failed to implement any measures to ensure compliance with limit values; most proposed measures were reportedly only at the preparatory stage and likely to be effective as late as 2024. It is unclear what, if any, measures were put in place to address this following the most recent referral (December 2020). Additionally, SO2 data indicate persistent non-compliance with hourly and daily mean limit values in the country’s South-East zone, where the four largest power plants are located. In July 2019, Bulgaria was referred to the Court of Justice regarding failures to respect limit values for SO258. The EEA also estimates the percentage of urban populations exposed to concentrations of air pollutants above the corresponding EU standards. In 2019, 58% of the urban population in Bulgaria was estimated to be exposed to annual levels of BaP exceeding the target value, and 60% were exposed to concentrations of PM10 exceeding the daily mean limit values. By contrast, less than 1% of the urban population was exposed to NO2 levels exceeding the annual mean limit value. Consequently, the urban pollutants of primary concern in Bulgaria are PM10 and BaP, and PM2.5 to a lesser extent. However, it is important to note that there are only eight urban monitoring locations that measure PM2.5 in Bulgaria and some of them were not operational during 2018 and/or 2019. Table 3: Percentage of urban population in Bulgaria exposed to concentrations above EU standards59 Pollutant 2015 2016 2017 2018 2019 BaP Annual mean 55.2 66.8 64.2 63.2 57.9 NO2 Annual mean 0.2 6.9 0.0 0.0 0.0 O3 Percentile 93.15 0.0 0.0 0.0 0.0 0.0 PM2.5 Annual mean 44.3 25.0 76.8 30.4 25.0 Annual mean 60.2 59.2 71.9 56.6 47.9 PM10 Percentile 90.41 78.9 90.7 75.7 65.4 59.9 Bulgaria operates a National Atmospheric Air Quality Monitoring System with 48 monitoring sites in 2019, of which 34 are automatic monitoring stations. Measurements of PM 10 are made at 41 sites, while 10 measure PM2.5. Monitoring for 201960 indicated continued exceedance of the annual mean limit value for NO2 in Plovdiv, although the hourly mean limit value was complied with across the monitoring network. In addition, no exceedances of the annual mean PM2.5 limit value were registered in 2019. While PM2.5 measurements did not exceed the annual mean limit value in 2019, Bulgaria has reported exceedances in some of its zones. Monitoring data also show that the daily mean limit value for PM10 was breached at 20 out of 41 monitoring sites, linked primarily to heating and solid fuel use during the winter season, as well as road transport emissions. Annual air quality reports are published by the Executive Environment Agency and are accessible online61. Data on the number of different sites measuring selected pollutants in Table 4. 58 EC. 2019. Air Quality: Commission refers Bulgaria and Spain to the Court for failing to protect citizens from poor air quality. https://ec.europa.eu/commission/presscorner/detail/EN/IP_19_4256 59 EEA. 2021. Bulgaria – Air pollution country fact sheet. https://www.eea.europa.eu/themes/air/country-fact-sheets/2021- country-fact-sheets/bulgaria 60 Executive Environment Agency. 2020. Atmospheric Air Quality. http://eea.government.bg/bg/soer/2019/air/kachestvo- na-atmosferniya-vazduh 61 Execuive Environment Agency. n.d. National reports from previous years. http://eea.government.bg/bg/soer/soer-arhiv 40 Sustainable Cities Implementation Framework – Air Quality Table 4: Monitoring stations used to report data to the European Environment Agency Pollutant Traffic Urban/suburban Industrial Rural Total background PM10 4 32 2 2 40 PM2.5 0 7 0 2 9 NO2 4 17 2 2 25 BaP 2 11 0 2 15 CURRENT STATUS AND GAP ANALYSES POLICY AND LEGISLATION The European Commission’s 2019 EIR review concluded that air quality requires “… special priority both at central and local levelâ€? and identified the following priority actions for Bulgaria (for air pollution and industrial pollution control)62: ï‚· Take action to reduce the main emission sources, in the context of the forthcoming National Air Pollution Control Programme (NAPCP) [subsequently submitted in 2020 and discussed below63]. ï‚· Accelerate the reduction of nitrogen oxide (NOx) emissions and nitrogen dioxide (NO2) concentrations. This will require, for example, further reductions in transport emissions — particularly in urban areas (and may require proportionate and targeted urban vehicle access restrictions) and/or fiscal incentives. ï‚· Accelerate reductions in particulate matter (PM2.5 and PM10) emissions and concentrations; this will require, for example, further reductions in emissions from heat generation and energy production using solid fuels, or the promotion of efficient and clean district heating. ï‚· Upgrade and improve the air quality monitoring network, and ensure timely reporting of air quality data. ï‚· Build on the “Coal regions in transitionâ€? initiative64 to reduce the use of coal for domestic heating in order to limit air pollutants emissions. ï‚· Review permits to comply with new BAT conclusions. ï‚· Strengthen control and enforcement to ensure compliance with BAT conclusions. ï‚· Address the pressure on the power sector arising from the need to comply with emission limit values under the IED and with the recently adopted implementing rules on BAT and associated emission levels for that sector, to be implemented by August 2021. Several interlinked national programs have been developed to address the issue of poor air quality; these include the “National Air Quality Improvement Program 2018-2024â€? (NAQIP) and “National Air Pollution Control Program 2020-2030â€? (NAPCP)65 which have been prepared by Bulgaria in order 62 https://ec.europa.eu/environment/eir/pdf/report_bg_en.pdf 63 https://ec.europa.eu/environment/air/pdf/reduction_napcp/BG%20final%20NAPCP%2026Sept19.pdf 64 The Initiative for coal regions in transition assists EU countries and coal regions tackling challenges related to the transition to a low-carbon economy. Further details here: https://ec.europa.eu/energy/topics/oil-gas-and-coal/EU-coal-regions/coal- regions-transition_en 65 https://ec.europa.eu/environment/air/reduction/NAPCP.htm 41 to fulfill its obligations under the AAQD and NECD, respectively, and demonstrate progress towards, and further actions to be implemented, to meet the relevant limits and commitments in the Directives. The NAQIP (2018-2024) includes measures targeting sectors identified as having a major contribution to fine particulate matter pollution – domestic heating and transport. This has then informed the development of the more recent NAPCP (2019). Hence the main policy options considered within the NAPCP, and proposed to be adopted to achieve compliance with Bulgaria’s emission reduction commitments for 2020 and 2030, target the residential heating and road transport sectors (and agriculture although as this is not relevant for air quality in cities in terms of actions that cities can take to reduce emissions, measures for this sector are not presented here). The measures include the following: ï‚· For residential heating (proposed to be adopted between 2019 and 2030): o Introduction of national requirements for coal quality, surrogate measures to reduce the moisture content of firewood used in municipalities that fail PM10 limit values and, potentially, a maximum moisture content requirement for firewood [in those areas]. o Bring forward the date at which Regulation (EU) 2015/1185 with regard to eco-design requirements for solid fuel local space heaters comes into effect; and a compulsory, accelerated phase-out of traditional, polluting solid-fuel heating appliances (stoves) in municipalities where ambient air quality has not complied with PM10 limit values; coupled with: o Households affected by the compulsory phase-out of traditional stoves to switch to heating by natural gas, district heating, electricity or eco-design-compliant heating appliances. ï‚· For road transport (proposed to be adopted between 2019 and 2024): o Modernization of vehicle fleet through allowing “cleanerâ€? imports only. o Establishing low emission zones (LEZs) in Sofia and Plovdiv to limit the demand for access of older, polluting types of road vehicle. The European Commission has undertaken an in-depth review of the NAPCPs and emission projections submitted by the Member States under the NECD 66 . For Bulgaria, the review has concluded that there is a high risk of non-compliance with the emission reduction commitments for NOx, NMVOCs and NH3 for 2020-29 and 2030 onwards due to the low margin of compliance projected and the poor quality of the emission projections. For PM2.5 there is a low risk of non-compliance which is important in the context of Bulgaria’s challenges with meeting air quality limits for PM. The Bulgarian NAPCP itself notes that achieving the emission reduction commitments within the NECD is dependent on the suite of measures being implemented according to the timescales set out. In particular, the programme notes that there are a number of implementation challenges for the measures targeting the residential heating and road transport sectors. In particular, the residential heating package of measures is expected to meet some opposition and therefore effective communication on the benefits and needs for such actions will be essential. Suitable financing will also need to be secured. 66 https://ec.europa.eu/environment/air/pdf/reduction_napcp/Horizontal%20review_final%2010Jun20.pdf 42 Sustainable Cities Implementation Framework – Air Quality A follow-up World Bank technical note 67 has sought to further develop and support the implementation of the residential heating measures that were identified in Bulgaria’s NAQIP and NAPCP (both of which were themselves developed with World Bank support). The technical note aims to identify where further support at national and local levels is needed to implement the measures set out in both programmes within the timetable specified (up to 2030). It also provides suggestions for effective support mechanisms and possible options for strengthening implementation based around the following three pillars: ï‚· a clear and empowering regulatory framework; ï‚· municipal capacity for planning and implementing effective measures in the residential heating sector; and ï‚· implementation funding that is focused on achieving core objectives, efficient, and effective. A summary of the key measures from the NAQIP and NAPCP is provided in Figure 9 along with a split of how the measures may be implemented at a national and local level. Whilst there are various important national level measures and supporting legislation, the bulk of implementation will need to take place at the local level to realize the full benefits. Figure 9: Summary of national and local NAQIP and NAPCP measures Source: Authors’ elaboration based on Bulgaria’s NAQIP and NAPCP. The note concludes that whilst the policy and regulatory framework is in place to tackle PM emissions, enhanced governance will be essential to bring about the desired outcomes. This includes 67 https://openknowledge.worldbank.org/bitstream/handle/10986/34145/Supporting-the-Implementation-of-Residential- Heating-Measures-in-Bulgaria-s-National-Air-Quality-Improvement-Program-NAQIP-and-National-Air-Pollution-Control- Program-NAPCP-Technical-Note.pdf?sequence=4 43 enhanced co-ordination on information exchange and collaboration between relevant stakeholders and the key implementing bodies i.e. the Ministries, Executive Agencies, and municipalities. This collaboration also needs to provide the municipalities with the incentives to implement the measures required and clarity on legal powers and basis by which they can take action. Alongside clarity on, and improvements to governance, effective communication to the public is necessary to gain “buy-inâ€? to the measures and the benefits they may bring. Finally, the scope and design of local programs targeted at residential heating (including eligibility criteria for funding) should take into account energy efficiency and climate change policies to ensure that they deliver maximum co-benefits. At a city level, of the four cities considered within Bulgaria in this report, Sofia is the most proactive in taking action to improve air quality and, more widely, to improve the local environment. This is driven, to some extent, by it being the largest, by far, of the cities in Bulgaria and thus faces the greatest challenges with respect to air quality and other environmental pressures. It also has the most active civil society and organizations. Some of the specific actions being taken by Sofia are described in the boxes below. Box 3: Sofia’s action plan to reduce emissions of PM10 and achieve AAQD standards Sofia (along with all other non-compliant cities, as required by national and EU legislation) adopted an action plan specifically targeted at reducing emissions of PM 10 and achieving the AAQD standards (“Program of atmospheric air quality management of Sofia Municipality for the period 2015-2020. - emission reductions and the achievement of established PM10 fine particulate matter standards (AQM Program)â€?. The programme had the following aims and objectives: ï‚· Reduce the air pollution levels on the Municipality’s territory for the perio d 2015-2020; ï‚· Comply with EU Air Quality Directive limits for PM; ï‚· Reduce human health risks; ï‚· Reduce pollution from transportation and residential heating, construction works, sanding and cleaning activities; ï‚· Define measures for improving air quality. Whilst PM10 concentrations have been falling in recent years, some exceedances were still observed based on 2019 data (and infringement proceedings are still underway) so it is unclear whether the programme has fully achieved its objectives yet or if it has been fully implemented already. Box 4: EBRD Green Cities Program in Bulgaria 68 The EBRD Green Cities program aims to build a better and more sustainable future for cities and their residents based around three central components: (i) Green City Action Plans (GCAPs), (ii) Sustainable infrastructure investment and (iii) Capacity-building. Of the four cities considered within this deep-dive report, Sofia and Varna have both joined the Green Cities programme. However, to date, only Sofia has developed and published a GCAP69. Sofia’s 2020 GCAP sets out the municipality’s actions to create a “green, clean municipality, full of lifeâ€? based around delivering seventeen key actions over the next 3-5 years across five priority sectors. Of relevance to air quality (and climate change), the plan aims to address the following challenges: ï‚· Residential heating: Sofia Municipality has a significant number of households using solid fuels and low-efficient heating systems which contributes to poor air quality during the heating (winter) season. ï‚· Transport: Sofia Municipality currently has a large share of relatively old private vehicles with high emissions. In response to these challenges, the plan includes a number of measures to shift the population to active travel (i.e. walking and cycling), improve public transport (including e.g. a tram renewal programme), to 68 https://www.ebrdgreencities.com/about 69 https://www.ebrdgreencities.com/assets/Uploads/PDF/7181e1a1c8/Sofia-GCAP_ENG.pdf 44 Sustainable Cities Implementation Framework – Air Quality promote and incentivize the uptake of cleaner vehicles, to improve the energy efficiency of municipal and residential buildings and to reduce solid fuel usage for building heating. Sofia is in a good position to implement their GCAP for the following reasons, all of which are relevant when considering actions for improving air quality: • Local governance: Sofia Municipality already has a number of existing action plans, programmes and policies that complement further actions in the GCAP. • Public perception: Sofia Municipality has a young population which is considered positive for supporting actions which will improve quality of life (including improving air quality). There are also a number of environmental NGOs operating in the Municipality which contribute to a greener city development. • Greater autonomy: The Municipality is receiving greater autonomy to manage policies and budget at local level. • Strong financial position: The Municipality has a strong credit rating and the ability to raise its own revenue at local level, relying to a limited extent on the central government (30% from budget). Sofia is already receiving investments from international donors. INSTITUTIONS AND CAPACITIES The public administration structure in Bulgaria reflects the three administrative tiers of the state, namely national, regional and local. The Ministry of Environment and Water (MoEW) is the national competent authority for environment issues in Bulgaria including the prevention and control of air pollutant emissions. The MoEW is responsible for the drafting and implementation of national environmental policy including the transposition of EU legislation into national law. It is also responsible for the coordination and management of financial resources on environmental issues. Other sectoral Ministries and State Agencies have relevant responsibilities for environmental protection, and work alongside the MoEW. Municipal mayors are ultimately responsible for air quality management at municipal level as per the Clean Ambient Air Act. In order to effectively develop and implement environmental policy, it is important that national, regional and local authorities deliver on their own tasks and work effectively with each other, within a multi-level governance system. The European Commission 2019 EIR report for Bulgaria70 highlights that the country has a governance score of 0.26, significantly below the EU average of 1.1, with regard to the government effectiveness index, as well as the regulatory quality index. It also sits at the bottom in the EU for the rule of law and control of corruption, so there is scope for improvement. Furthermore, the EIR found that Bulgaria’s approach to legal standing is still restrictive, with the courts typically blocking citizens and environmental NGOs from contesting the content of air quality plans. One of the priority actions included within the EIR was to ensure that there is legal standing for environmental NGOs to bring challenges on air pollution (amongst other topics). As discussed in the previous section, the World Bank Technical Note71, developed as a follow on to Bulgaria’s NAQIP and NAPCP, identified a need for enhanced governance to deliver the desired outcomes with the measures proposed. This included enhanced collaboration between relevant stakeholders and the key implementing bodies and providing municipalities with clarity on legal powers and basis by which they can take action. Furthermore, the note identified some capacity 70https://ec.europa.eu/environment/eir/pdf/report_bg_en.pdf 71 https://openknowledge.worldbank.org/bitstream/handle/10986/34145/Supporting-the-Implementation-of-Residential- Heating-Measures-in-Bulgaria-s-National-Air-Quality-Improvement-Program-NAQIP-and-National-Air-Pollution-Control- Program-NAPCP-Technical-Note.pdf?sequence=4 45 constraints (human and financial resources) at the municipality level that are likely to impact on their ability to prepare and implement effective stove replacement programmes which should form a core part of local Air Quality Plans. The review identified that staff numbers in environmental departments are often limited, particularly for small- and medium sized municipalities, and those focused on air quality will also be covering other topics. This is particularly challenging as the smaller municipalities often have a greater share of households using solid fuels for heating. These resource constraints also restrict funding applications, where the process is seen to be burdensome. As a result, the note concludes that capacity constraints mean that external support will be necessary for effectively implementing a stove replacement programme e.g. for collecting data to prepare source and emission inventories, undertaking pollutant dispersion modelling, planning practical steps such as the safe disposal of stoves that are removed, communications with the general public, economic evaluation of measures, and funding application support. As there is limited in-country experience of stove replacement programmes, the note proposes the establishment of a centralized Technical Support Unit (TSU) to provide the necessary expertise and support to municipalities. FINANCING Limited information has been identified on historical spending on air quality improvements in Bulgaria. Bulgaria spent just over EUR 300 million on environmental protection overall in 2016, a 15 % decrease from 201572. Bulgaria has been allocated significant funds under European structural and cohesion funds e.g. European Structural and Investment Funds (ESIF). These funds are key instruments for comprehensive environmental protection in the EU. One of the priority actions identified in the 2019 EIR for Bulgaria 73 was to mobilize investment, including through EU funds, for environmental protection including addressing air pollution. Furthermore, the EIR identified that there are no CO2-based taxes for road vehicles and incentives to purchase low emission vehicles were rare (at least in 2016). The World Bank Technical Note74 focused on further advancing implementation of measures for reducing domestic emissions, identified a number of conclusions and recommendations for the successful implementation of the measures in relation to financing: ï‚· Sufficient funding for the stove replacement programmes is essential for their success and they need to be made available and distributed in an efficient and effective manner. Potential funding sources are likely to include EU funds and/or national resources. ï‚· The NAQIP identified Operational programme “Environmentâ€? (OPE) 2021-2027 as the main source of funding (the previous OPE is currently running and has some funding for stove replacement). These funds should be allocated based on clear prioritization and eligibility criteria and capacity at local level. Some of these funds could be allocated for a financial instruments scheme with preferential loans or loan guarantees being made available to eligible households. This could help to leverage additional funding from a range of other sources including private investors and international financial institutions. Income-based 72https://ec.europa.eu/environment/eir/pdf/report_bg_en.pdf 73https://ec.europa.eu/environment/eir/pdf/report_bg_en.pdf 74 https://openknowledge.worldbank.org/bitstream/handle/10986/34145/Supporting-the-Implementation-of-Residential- Heating-Measures-in-Bulgaria-s-National-Air-Quality-Improvement-Program-NAQIP-and-National-Air-Pollution-Control- Program-NAPCP-Technical-Note.pdf?sequence=4 46 Sustainable Cities Implementation Framework – Air Quality graduated grant schemes and related financial instruments should be considered to help support and protect low-income households that may be unable to pay for replacement of stoves. ï‚· Fiscal incentives in the form of income tax credits or rebates/deductions for investments made in eligible appliances or projects, coupled with financial support mechanisms (such as partial grant financing) and financial instruments (such as preferential loans) should be considered to further incentivize uptake and replacement of stoves. ï‚· As described in the previous section, the note recommends the set-up of a Technical Support Unit (TSU) whose remit could also include financial aspects (as well as the technical elements described previously). Box 5: Funding sources for Sofia's Green City Action Plan Sofia’s GCAP has reviewed and identified which funding sources are considered the best fit for the actions prioritised in the plan. For those related to air quality and climate change improvements (focused on the transport and buildings sectors), the main sources considered a good fit (i.e. to be prioritized in further research as the finance source is well matched to the scale of the intervention) included funding from multilateral development banks, EU funds and municipality budgets. Selected measures were also considered a good fit for national level funding sources. RECOMMENDATIONS As described in the sections above, the key challenges for Bulgaria and the cities considered relate to NOx and PM emissions, primarily due to transport and domestic heating. As a result, the key recommendations relate to these specific sectors and build on the priority actions identified in the 2019 EIR report and the NAPCP for Bulgaria: ï‚· Accelerate the reduction of NOx emissions focused on delivering further reductions in transport emissions, particularly in urban areas. This is likely to require a broad suite of measures including proportionate and targeted urban vehicle access restrictions, improved technical inspections of existing vehicles, fiscal incentives for the purchase of low emission vehicles, investments in the necessary infrastructure to support switching to electric vehicles (e.g. charging infrastructure) and further investments in public transport in cities to help to reduce personal car usage. Some measures targeted at the transport sector have already been set out in Bulgaria’s NAPCP plus further measures specifically for Sofia within its GCAP. ï‚· Accelerate reductions in PM (PM2.5 and PM10) emissions focused on achieving further reductions in emissions from heat generation and energy production using solid fuels (particularly in the domestic sector) by supporting the switch away from the use of solid fuels (e.g. switching to electricity) and/or the development and promotion of efficient and clean district heating. The measures have already been identified in the NAQIP and NAPCP and should be implemented within the timescales set out. Initiatives such as that focused on the “Coal regions in transitionâ€? initiative75 should be utilized to support such actions to reduce the use of coal for domestic heating. 75The Initiative for coal regions in transition assists EU countries and coal regions tackling challenges related to the transition to a low-carbon economy. Further details here: https://ec.europa.eu/energy/topics/oil-gas-and-coal/EU-coal-regions/coal- regions-transition_en 47 ï‚· Enhanced co-ordination on information exchange and collaboration between relevant stakeholders and the key implementing bodies i.e. the Ministries, Executive Agencies, and municipalities. This should provide the municipalities with the incentives to implement the measures required and clarity on legal powers and basis by which they can take action. ï‚· Effective communication to the public is necessary to gain “buy-inâ€? to the measures and the benefits they may bring. ï‚· Upgrade and improve the air quality monitoring network, and ensure timely reporting of air quality data as well as making it available to the general public. ï‚· To support additional actions to reduce emissions of NOx and PM, Bulgaria should consider ways in which investment could be further mobilized, including through use of EU and other funding programmes. Different instruments for the allocation and use of the funds should also be considered to help leverage other funding sources as well as to use the resources in the most efficient and effective way e.g. whilst protecting low-income households. 48 Sustainable Cities Implementation Framework – Air Quality CROATIA URBAN CONTEXT BASIC DEMOGRAPHIC AND SPATIAL INDICATORS76 POPULATION SPACE Population: 4 047 200 inhabitants (2020) Area: 88 070 km2 Urban Population: 58% Settlement area: 722.5 m2 / capita 77 Pop. in Urban Agglomeration > 1 mil. (% total): 0% Population Density: 72 inhabitants / km2 Population Change: -2.8% (2015-2018), -4% since 2012 Built-up area change: 4.67% (2015-2018) Population Growth Rate: -0.48% (2015-2018) Land Consumption Rate: 1.5% (2015- 2018) 78 EEA CITY AIR QUALITY RANKING ON THE LEVEL OF PM2.5 MEAN CONCENTRATIONS OVER 2019 & 202079,80 CITY SPLIT ZAGREB EU ranking No data 256/323 Fine particulate matter (PM2.5) in No data 15.8 μg/m3 City’s population (National %) 179 105 (4.44%) 787 619 (19.46%) This chapter examines the air quality and concentration of pollutants in Croatia, while deep diving into two urban settings: Split and Zagreb. It examines the sources and prevalent pollutants at national and urban settings in Croatia. Furthermore, it analyzes the challenges and trends of the pollutants and assesses the gaps and impacts through three areas: Policy & Legislation, Institutions & Capacity, and Financing. Finally, policy recommendations for air pollution prevention, reduction and abatement are presented. EMISSION TRENDS Croatia’s IIR for 202181 identifies the trends in pollutant emissions and source sectors; these data are summarized in Table 5. The data indicate that SO2 emissions have declined sharply between 1990 76 Data source: World Bank Data (population and geography), Eurostat (land consumption) 77 EU-27 average: 703.4 m2 / capita 78 Data source: World Bank Data (population and geography), Eurostat (land consumption) 79 EEA. 2021. European city air quality viewer. https://www.eea.europa.eu/themes/air/urban-air-quality/european-city-air- quality-viewer 80 Cities marked as “No dataâ€? have not been included in the EEA “European city air quality viewerâ€? for one of the three reasons below: ï‚· The city does not have urban or suburban air quality monitoring stations. ï‚· The urban and/or suburban air quality monitoring stations in the city have not reported data covering 75% of the days in the year. ï‚· The city is not included in the database of cities established under the European Commission’s Urban Audit. 81 Republic of Croatia Ministry of Economy and Sustainable Development. 2021. Republic of Croatia 2021 Informative Inventory Report (1990-2019). 49 and 2019. NOx emissions have approximately halved over the period, with reductions of 19% and 26% in PM10 and PM2.5 emissions respectively. Table 5: Pollutant emission and source sector trends in Croatia, 1990-2019 Pollutant Emissions (kt) Key sectors 1990 2019 Reduction SO2 169 8 95% Manufacturing and construction 33% Fugitive emissions 30% Energy industries 25% NOx 111 54 52% Road transport 43% “Other sectorsâ€? 14% Agriculture 14% NMVOC 170 75 56% Industrial processes and product use 48% Small combustion and mobile machinery 26% Agriculture 12% Road transport 6% NH3 56 37 35% Agriculture 86% Small combustion and mobile machinery 7% PM10 51 41 19% Small combustion 55% Industrial processes and product use 27% Agriculture 8% PM2.5 39 29 26% Small combustion and mobile machinery 76% Industrial processes and product use 11% Road transport 5% Sectoral emissions time series data from the EEA’s country fact sheet for Croatia82 are displayed in Figure 10 and Figure 11. The data indicate that emissions of both NOx and PM2.5 have steadily declined between 2010 and 2019. In 2019 road transport accounted for 43% of Croatia’s NOx emissions, with agriculture, manufacturing and extractive industries, and residential sectors accounting for 18%, 12% and 10% respectively. In terms of PM2.5, the residential, commercial and institutional sector has consistently been the greatest contributor to national emissions since 2010, accounting for 76% of emissions in 2019. Manufacturing and extractive industries contribute a further 12%. Note: figures are displayed with divisions within sectors to represent unlabeled sub-sectors; for example, transport is divided into road and non-road transport. 82 EEA. 2019. Croatia – Air pollution country fact sheet. https://www.eea.europa.eu/themes/air/country-fact-sheets/2021- country-fact-sheets/croatia-1 50 Sustainable Cities Implementation Framework – Air Quality Figure 10: Total NOx emissions timeseries by sector for Croatia Figure 11: Total PM2.5 emissions timeseries by sector for Croatia TRENDS BY KEY SOURCE SECTOR ENERGY INDUSTRIES Croatia’s energy production has been reliant on fossil fuels, with oil and gas contributing 38% and 30% to total energy supply in 2019. By contrast, coal constitutes only a minor part of the energy mix (5% in 2019) and as done so since 1990. Use of hydro power, biofuels and waste, and wind, solar and other renewables has increased steadily, although oil and natural gas continue to dominate the energy supply. 51 Figure 12: Total energy supply in Croatia by energy source, 1990-201983 TRANSPORT Road transport is the main source of Croatia’s NOx emissions, accounting for approximately 43% of emissions in 2019. Between 1990 and 2019, fuel consumption in road transportation has increased by 68%81, accompanying increased numbers of road vehicles. The number of passenger cars declined from 1.1 million to 750,000 in 1994, thereafter increasing steadily to over 1.7 million in 2019. Similarly, numbers of LDVs and HDVs have increased from 69,000 and 40,000 respectively in 1990 to 148,000 and 54,000 in 2019 (see Figure 13). 83 IEA. 2019. Country profile: Croatia. https://www.iea.org/countries/croatia 52 Sustainable Cities Implementation Framework – Air Quality Figure 13: Registered vehicle numbers in Croatia, 1990-201981 Compared to the average passenger car age in the EU in 2019 (11.5 years), Croatia’s vehicle fleet is relatively old, with an average passenger car age of 14.6 years84. Additionally, uptake of electric and hybrid vehicles in Croatia is low, with petrol and diesel vehicles dominating the passenger car fleet mix (47% and 52% respectively), with only 0.2% hybrid electric vehicles. Uptake of newer and cleaner vehicles, as well as electric and low emissions vehicles, has therefore been limited in Croatia, with implications for air quality in urban areas. OTHER FUEL COMBUSTION SOURCES (INCLUDING RESIDENTIAL) From 2010 to 2019, the residential, commercial and institution sectors have been the main contributors to PM2.5 emissions (Figure 11). Residential emissions are the primary component within in Croatia, and data on fuel consumption indicate that biomass is the main fuel used in the residential sector. Residential fuel consumption steadily increased from 1990 to a peak in 2005 and has gradually decreased since. This is likely due to increased uptake of more efficient stoves as well as switching to electricity and district heating. For example, in Croatia’s IIR it states that in 2005 the total market share of advanced/eco-label and high efficiency stoves was 0% in 2005 but increased to over 30% by 2017. 84 ACEA. 2021. Vehicles in use Europe. https://www.acea.auto/files/report-vehicles-in-use-europe-january-2021-1.pdf 53 Figure 14: Residential fuel consumption by fuel type in Croatia, 1990-201981 AIR QUALITY TRENDS The EEA estimates that in 2019 4,200 premature deaths could be attributed to fine particulate matter concentrations and a further 170 deaths were attributable to NO2 exposure53. In its review of the implementation of the NECD85, the European Commission concluded that, despite projected compliance with all commitments for 2020 and 2030, Croatia is at medium risk of non-compliance with commitments for PM2.5 for both 2020 and 2030. The Environmental Implementation Review (EIR)Error! Bookmark not defined. for Croatia concludes that additional efforts are required to fulfill emission reduction commitments. In addition, data reveal continued exceedances of the PM10 and PM2.5 Limit Values in the cities of Zagreb and Osijek as well as the industrial zone encompassing Slavonski Brod. The EEA82 has produced maps and graphs illustrating air quality in Croatia in 2019; these are displayed in Figure 15, Figure 16 and Figure 17. The maps on the left show air quality monitoring stations in the country and the concentrations of pollutant measured at each station. The graphs on the right present trends in annual mean concentrations since 2010 by station type. For PM10 measurements, the 90.41 percentile of annual measurements is presented, which approximates compliance with the daily limit value. The daily mean limit value for PM10 was complied with in 2019 at most monitoring sites except for an urban background site in Zagreb, an urban traffic location in Osijek, and two other urban monitoring sites. The urban traffic site in Split registered compliance in 2019. All monitoring sites were compliant with the annual mean NO2 limit value except for a Zagreb urban traffic location. Monitoring of BaP was undertaken at three locations, two urban sites in Zagreb 85 EC. 2020. Annexes to the report from the Commission to the European Parliament and the Council on the progress made on the implementation of Directive (EU) 2016/2284 on the reduction of national emissions of certain atmospheric pollutants. https://eur-lex.europa.eu/resource.html?uri=cellar:7199e9c2-b7bf-11ea-811c- 01aa75ed71a1.0007.02/DOC_2&format=PDF 54 Sustainable Cities Implementation Framework – Air Quality and an industrial site, all of which recorded exceedances of the annual mean target value. The accompanying time series show that with the exception of a spike in 2013, there are no discernible trends in PM10 concentrations since 2010. Concentrations of NO2 have generally declined over the same period, and BaP concentrations peaked in 2015, since declining thereafter. Figure 15: PM10 measurement data and measurement locations in Croatia Figure 16: NO2 measurement data and measurement locations in Croatia 55 Figure 17: BaP measurement data and measurement locations in Croatia For the purpose of assessment against limit and target values set out in the Ambient Air Quality Directive, Croatia’s territory is divided into five zones (Continental Croatia; Industrial Zone; Lika, Gorski Kotar and Primorje; Istria; and Dalmatia) and four agglomerations (Zagreb, Osijek, Rijeka, and Split). In 2020, the following exceedances of EU limit and target values were registered: ï‚· Daily mean PM10 limit value and BaP target value in the Zagreb agglomeration; ï‚· Daily mean PM10 limit value in the Osijek agglomeration; ï‚· Daily mean PM10 limit value, annual mean PM2.5 limit value, and BaP target value in the Industrial Zone; and ï‚· Ozone target value in the Istria and Dalmatia zones. As a result of these infringements, the European Commission urged Croatia to take action to comply with AAQD requirements in October 2020, and noted that measures taken to minimize air pollution were insufficient to keep exceedance periods as short as possible86. EEA country profiles also provide an estimate of the percentage of urban populations living in areas exposed to pollutant concentrations in breach of EU limit values. 100% of the urban population was estimated as being exposed to BaP concentrations exceeding the target value, and 95% was exposed to PM10 levels exceeding the daily mean limit value. By contrast, fewer than 4% of the urban population was exposed to NO2 concentrations above the annual mean limit value. Table 6: Percentage of urban population in Croatia exposed to concentrations above EU standards87 Pollutant 2015 2016 2017 2018 2019 BaP Annual mean 100.0 100.0 100.0 100.0 100.0 NO2 Annual mean 3.3 3.3 3.3 0.0 3.5 O3 Percentile 93.15 93.6 80.6 99.5 0.0 0.0 86 EC. 2020. October infringements package: key decisions. https://ec.europa.eu/commission/presscorner/detail/EN/INF_20_1687 87 EC. 2021. Croatia – Air pollution country fact sheet. https://www.eea.europa.eu/themes/air/country-fact-sheets/2021- country-fact-sheets/croatia-1 56 Sustainable Cities Implementation Framework – Air Quality Pollutant 2015 2016 2017 2018 2019 PM2.5 Annual mean 30.1 26.0 26.2 29.4 29.4 Annual mean 43.0 49.6 49.5 49.5 49.5 PM10 Percentile 90.41 86.0 99.1 99.1 99.1 95.0 Annual assessment is conducted through fixed point monitoring as well as modelling. This includes a national air quality monitoring network with 22 monitoring locations in 2020, and a further 47 monitoring locations operated by local and regional bodies88, including city and municipal authorities. A breakdown of monitoring locations reported to the European Environmental Agency is given in Table 7, listed by site type for selected pollutants. Table 7: Monitoring stations used to report data to the European Environment Agency Pollutant Traffic Urban/suburban Industrial Rural Total background PM10 4 1 1 5 11 PM2.5 1 4 0 5 10 NO2 4 7 0 2 13 BaP 1 1 1 0 3 Historic and real-time monitoring data from Croatia’s national and local monitoring networks are available from the Ministry of Economy and Sustainable Development; these are publicly accessible via an online portal89. In addition, both the Ministry of Economy and Sustainable Development88 and local authorities, including the City of Zagreb90, have produced annual reports summarizing monitoring results across the network(s). A summary of city-specific monitoring is provided in the box below. Box 6: City-Specific Monitoring: Croatia In 2020, six monitoring sites were operational in Zagreb. These include the following urban traffic locations: ï‚· Ä?orÄ‘ićeva ulica (NO2, PM10 amongst others), ï‚· Prilaz baruna Filipovića (NO2, PM10) ï‚· Siget (NO2, BaP, PM10) In addition, the city operates industrial monitoring sites at PeÅ¡Ä?enica (NO2, PM10) and Susedgrad (NO2, PM2.5, PM10), as well as a site at an urban background location Ksaverska cesta (NO 2, PM10, BaP, PM2.5). NO2 and PM10 measurements at all six sites were compliant with the AAQD annual mean limit value in 2020, although all six sites exceeded the daily mean limit value for PM10. Four continuous monitoring sites are operational in Split at locations in Gripe, Visoka, Poljud and Žrnovnica. 88 Republika Hrvatska Ministarstvo gospodarstva i održivog razvoja. 2021. Izvješće o praćenju kvalitete zraka na teritoriju Republike Hrvatske za 2020. godinu http://iszz.azo.hr/iskzl/datoteka?id=127707 89 Republika Hrvatska Ministarstvo gospodarstva i održivog razvoja. n.d. Kvaliteta zraka u Republici Hrvatskoj http://iszz.azo.hr/iskzl/index.html 90 Institut za Medicinska Istraživanja i Medicinu Rada Zagreb. 2020. IZVJEÅ TAJ O MJERENJU I PRAĆENJU KVALITETE ZRAKA NA GRADSKIM MJERNIM POSTAJAMA U 2020. http://iszz.azo.hr/iskzl/datoteka?id=121079 57 CURRENT STATUS AND GAP ANALYSES POLICY AND LEGISLATION The European Commission’s 2019 EIR review concluded that air quality in Croatia “…is giving cause for concernâ€? and identified the following priority actions (for air pollution and industrial pollution control)91: ï‚· In the context of the forthcoming National Air Pollution Control Programme (NAPCP), take measures to reduce the main sources of emissions; [NAPCP was subsequently submitted in 2019 and is discussed further below] ï‚· Accelerate reductions of particulate matter (PM2.5 and PM10) emissions and concentrations. This will require, for example, further reduction of emissions from energy production and heat generation using solid fuels, and promotion of efficient and clean district heating; ï‚· Accelerate reduction of nitrogen oxide (NOx) emissions and nitrogen dioxide (NO2) concentrations. This will require, for example, further reducing transport emissions, in particular in urban areas (and may require proportionate and targeted urban vehicle access restrictions) and/or fiscal incentives; ï‚· Reduce ammonia (NH3) emissions to comply with currently applicable national emission ceilings, for example by introducing or expanding the use of low emission agricultural techniques; ï‚· Review permits to ensure they comply with the newly adopted BAT conclusions; ï‚· Strengthen control and enforcement to ensure compliance with the BAT conclusions; and ï‚· Address the challenge implementing BAT in the waste treatment sector. Historically, the national air protection policy is defined by the Air Protection, Ozone Layer and Climate Change Mitigation Plan in the Republic of Croatia for the Period 2013-2017 (NN No 139/13). More recently, Croatia submitted an NAPCP to the European Commission under the NECD in October 201992. This included a series of policies and measures proposed for adoption in order to further reduce emissions of NOx, PM2.5 and NH3. The measures proposed for sectors of relevance for improving urban air quality (namely buildings and road transport) are described relatively briefly so it is unclear exactly what will ultimately be implemented; these include the following: ï‚· Measures targeted at buildings: efficiency improvement of buildings; reduction of losses; efficiency improvement of appliances. ï‚· Measures targeted at transport: deployment of emission reduction technologies on vehicles; efficiency improvement of vehicles; modal shift to public transport or non-motorized transport; alternative fuels / electric cars; demand management/reduction; improved behavior; improved transport infrastructure; promoting the use of bicycles. The NAPCP also includes measures “to increase the administrative, technical and management capacities of local communitiesâ€? and “preparing supporting documentation to secure additional 91 https://ec.europa.eu/environment/eir/pdf/report_hr_en.pdf 92 https://ec.europa.eu/environment/air/pdf/reduction_napcp/HR%20final%20NAPCP%2011Oct19.pdf 58 Sustainable Cities Implementation Framework – Air Quality financial resources for more effective implementation of air quality improvement action plansâ€?. Both appear to relate to application of and/or use of EU funds to support air quality management. Split, the second-largest city in Croatia, joined EBRD Green Cities in 2020 with the aim of “addressing its environmental issues and improving the quality of life of its residentsâ€?93. A Green City Action Plan (GCAP) has not yet been published but is intended to take a systematic approach to address the key urban environmental challenges faced in the city with a series of targeted actions. The AAQD is implemented in Croatia through the Air Protection Act (NN No 127/19). Article 11 of the Act places a responsibility on the Government to develop an Air Protection Plan. Similarly, Article 13 requires the City of Zagreb to produce an Air Protection Program containing an assessment of air quality in the city and measures to improve air quality. Article 57 of the Act requires that this is made publicly available; a report setting out this information is available for 202094. The report includes measures such as expansion of pedestrian zones and cycling infrastructure, and expanding the natural gas distribution network. Zagreb also adopted a Sustainable Energy and Climate Action Plan in 201995. Whilst the main focus is on energy and climate change, one of the explicit goals of the plan is to “Increase the quality of life of its citizens (improve air quality, reduce traffic congestion etc.)â€?. A number of the measures in the plan are aimed at tackling climate change and improving energy efficiency, and will also have significant co-benefits for air quality. For example, a number of actions are targeted at improving public transport in order to reduce vehicle usage which will have benefits for both GHGs and air pollutants. INSTITUTIONS AND CAPACITIES The Ministry of Environment and Energy is the national authority for environmental policy implementation in Croatia96. This includes responsibility for air quality policy including adoption and implementation of measures to reduce emissions, running the national monitoring network, and reporting and making available relevant information. At local and regional levels, air quality activities are performed by municipal offices and county offices (including that of the City of Zagreb). The representative body of each county, City of Zagreb and major city is responsible for drafting and adopting an air quality action plan where air pollutant levels exceed any legislative limit or target values. In relation to communications, public and NGO access to justice and governance, the 2019 EIR identified the following priority actions for Croatia: ï‚· Inform the public better about their access to justice rights. ï‚· Ensure that there is legal standing for environmental NGOs to challenge all environmentally relevant permits and to bring challenges relating to nature or air. 93 https://www.ebrdgreencities.com/our-cities/split/ 94 http://iszz.azo.hr/iskzl/datoteka?id=128141 95 https://eko.zagreb.hr/UserDocsImages/arhiva/dokumenti/secap/City%20of%20Zagreb%20- %20Sustainable%20Energy%20and%20Climate%20Action%20Plan%20(SECAP).pdf 96 https://ec.europa.eu/environment/air/pdf/reduction_napcp/HR%20final%20NAPCP%2011Oct19.pdf 59 ï‚· Further improve overall environmental governance (such as transparency, citizen engagement, compliance and enforcement, as well as administrative capacity and coordination). Furthermore, in relation to administrative structures and governance, the World Bank’s 2018 Systematic Country Diagnostic97 identified reforms as being required in Croatia in order to address the following: ï‚· rigid organizational structures ï‚· overlapping functions ï‚· the politicization of the civil service ï‚· poor coordination ï‚· unclear accountability ï‚· fragmented and unsustainable subnational government structures. These challenges may have had and/or continue to have implications for environmental protection including for air quality. FINANCING Limited information has been identified on historical spending on air quality improvements in Croatia. Croatia spent around EUR 300 million on environmental protection overall in 2016, a 15% increase from 201598. However, only EUR 1.5 million was allocated to reducing pollution (0.5 % of total). Croatia has been allocated significant funds under European structural and cohesion funds e.g. European Structural and Investment Funds (ESIF). These funds are key instruments for comprehensive environmental protection in the EU. RECOMMENDATIONS As described in the sections above, the key challenges for Croatia and the cities considered for air quality relate to NOx and PM emissions, primarily due to transport and domestic heating. As a result, the key recommendations relate to these specific sectors and build on the priority actions identified in the 2019 EIR report and the NAPCP for Croatia: ï‚· Accelerate reductions in PM (PM2.5 and PM10) and BaP emissions in order to achieve the EU limit / target values. This should be focused on achieving further reductions in emissions from heat generation and energy production using solid fuels (particularly in the domestic sector) by supporting the switch away from the use of solid fuels (e.g. switching to electricity, renewables) and/or the development and promotion of efficient and clean district heating. Some measures have already been identified in the NAPCP but have only been described 97 World Bank, The Republic of Croatia systematic country diagnostic, 2018. https://documents1.worldbank.org/curated/en/452231526559636808/pdf/Croatia-SCD-clean-05142018.pdf 98 https://ec.europa.eu/environment/eir/pdf/report_hr_en.pdf 60 Sustainable Cities Implementation Framework – Air Quality briefly and at a relatively high level, so it is unclear what is planned to be implemented and by when99. The 2019 EIR report also identified a need for Croatia to update permits for industrial installations to reflect the latest emission standards and improve overall enforcement and compliance. Initiatives such as that focused in the “Coal regions in transitionâ€? initiative 100 should be utilized to support such actions to reduce the use of coal for domestic heating and energy production. Zagreb’s Sustainable Energy and Climate Action Plan sets out a number of actions targeted at the buildings and transport sectors, and Split is currently developing a Green City Action Plan, both of which should contribute to reducing air pollutant emissions in those sectors. ï‚· Accelerate the reduction of NOx emissions focused on delivering further reductions in transport emissions, particularly in urban areas. Whilst NO2 appears to be less of an issue in Croatia from a compliance perspective, one non-compliance was identified in Zagreb in 2019 so further reductions are required. It was also identified as a priority action in the 2019 EIR report. To reduce NOx emissions in urban areas is likely to require a broad suite of measures including proportionate and targeted urban vehicle access restrictions, fiscal incentives for the purchase of low emission vehicles, investments in the necessary infrastructure to support switching to electric vehicles (e.g. charging infrastructure) and further investments in public transport in cities to help to reduce personal car usage. Croatia’s vehicle fleet is relatively old and uptake of electric and hybrid vehicles is very low. Some measures targeted at the transport sector have already been set out in Croatia’s NAPCP although they are only described relatively briefly and exact plans and timescales for implementation are unclear101. ï‚· To support additional actions to reduce emissions of NOx, PM and BaP, Croatia should consider ways in which investment could be mobilized, including through use of EU and other funding programmes. Different instruments for the allocation and use of the funds should also be considered to help leverage other funding sources as well as to use the resources in the most efficient and effective way. Croatia’s NAPCP also includes measures for “preparing supporting documentation to secure additional financial resources for more effective implementation of air quality improvement action plansâ€? which appear to relate to application of and/or use of EU funds to support air quality management. ï‚· Enhanced co-ordination on information exchange and collaboration between relevant stakeholders and the key implementing bodies i.e. the Ministries, Municipal Offices and County Offices. This should provide local bodies with the incentives to implement the measures required and clarity on legal powers and basis by which they can take action as well as accountability for their actions. ï‚· Improve overall governance for air quality management (and other environmental issues) including transparency, citizen engagement, compliance and enforcement, as well as administrative capacity and coordination. Croatia’s NAPCP includes measures “to increase the administrative, technical and management capacities of local communitiesâ€? although it is 99 The NAPCP specifies measures for efficiency improvement of buildings, reduction of losses, and efficiency improvement of appliances. 100 The Initiative for coal regions in transition assists EU countries and coal regions tackling challenges related to the transition to a low-carbon economy. Further details here: https://ec.europa.eu/energy/topics/oil-gas-and-coal/EU-coal- regions/coal-regions-transition_en 101 These include deployment of emission reduction technologies on vehicles; efficiency improvement of vehicles; modal shift to public transport or non-motorised transport; alternative fuels / electric cars; demand management/reduction; improved behaviour; improved transport infrastructure; promoting the use of bicycles. 61 unclear exactly what this will mean in practice. The 2019 EIR identified priority actions for Croatia to inform the public better about their access to justice rights and to ensure that there is legal standing for environmental NGOs to challenge all environmentally relevant permits and to bring challenges relating to nature or air. 62 Sustainable Cities Implementation Framework – Air Quality POLAND URBAN CONTEXT BASIC DEMOGRAPHIC AND SPATIAL INDICATORS102 POPULATION GEOGRAPHY Population: 37,950,800 inhabitants (2020) Area: 312, 690 km2 Urban Population: 60% Settlement area: 633.7 m2 / capita 103 Pop. in Urban Agglomeration > 1 mil. (% total): Population Density: 214 inhabitants / km2 5% Population Change: -0.2% (2012-2018) Built-up area change: 6.5% (2012-2018) Population Growth Rate: -0.04% (2012-2018) Land Consumption Rate: 1% (2012-2018) EEA CITY AIR QUALITY RANKING ON THE LEVEL OF PM2.5 MEAN CONCENTRATIONS OVER 2019 & 2020104 CITY KATOWICE POZNAŃ WARSAW (zwiÄ…zek metropolitalny) EU ranking 312/323 275/323 269/323 Fine particulate matter (PM2.5) in 22.7 17.2 17.0 μg/m3 City’s population 1 927 767 (5.08%) 558 426 (1.47%) 1 710 269 (4.5%) (National %) This chapter examines the air quality situation in Poland, with a particular focus on three urban settings: Katowice, Poznan, and Warsaw. It examines the key sources and trends in emissions of air pollutants and resulting air quality. Furthermore, it analyzes the current status, challenges and gaps in air quality management focused on the following three areas: Policy & Legislation, Institutions & Capacity, and Financing. Finally, recommendations for further improving air quality are presented. EMISSION TRENDS Poland’s Informative Inventory Report (IIR) 2021105, submitted under the UNECE Convention on Long- range Transboundary Air Pollution and Directive (EU) 2016/2284, describes the national emission trends by both pollutant and source sector, from 1990 to 2019 (the latest year for which data is available). Significant progress has been made across all pollutants since 1990, as summarized in Table 8. 102 Data source: World Bank Data (population and geography), Eurostat (land consumption) 103 EU-27 average: 703.4 m2 / capita 104 EEA. 2021. European city air quality viewer. https://www.eea.europa.eu/themes/air/urban-air-quality/european-city- air-quality-viewer 105 Ministry of Climate and Environment. 2021. Poland’s Informative Inventory Report 2021. 63 Table 8: Pollutant emissions and key sectors for Poland, 1990 and 2019 Pollutant Emissions (kt) Key sectors 1990 2019 Reduction SO2 2,613 427 84% Energy Industries 49% Manufacturing industries 20% Fuel combustion “other sectorsâ€? 27% NOx 1,117 682 39% Transport 41% Energy industries 20% Agriculture 10% Fuel combustion “other sectorsâ€? 17% NMVOC 792 647 18% Industrial processes and product use 35% Agriculture 16% Transport 12% Fuel combustion “other sectorsâ€? 16% NH3 503 317 37% Agriculture 95% Transport 1% PM2.5 366 122 67% Fuel combustion “other sourcesâ€? 49% Manufacturing industries 20% Transport 11% Industrial processes and product use 9% While significant emissions reductions have been made since 1990, more recent trends have been less positive for all of the pollutants, other than SO2 where continuous downward trends have been maintained. NOx and NMVOC emission trends have largely stabilized since around 2015, while NH3 emissions have remained largely constant, and emissions of PM2.5 show only a slight downward trend. Time series data for emissions from different sectors in Poland106 are displayed in Figure 18 and Figure 19. Emissions of both NOx and PM2.5 have gradually decreased from 2010 to 2019. Road transport has consistently been a significant source of NOx emissions, accounting for 40% of emissions in 2019. NOx emissions from energy production have declined, but continue to represent 20% of emissions in 2019. With regard to PM2.5, the residential, commercial and institutional sector has been the dominant source of emissions, contributing 43% of the total in 2019; other major sources include manufacturing and extractive industries (29%) and road transport (11%). Note: figures are displayed with divisions within sectors to represent unlabeled sub-sectors; for example, transport is divided into road and non- road transport. 106 EEA. 2021. Poland – Air pollution country fact sheet. https://www.eea.europa.eu/themes/air/country-fact-sheets/2021- country-fact-sheets/poland 64 Sustainable Cities Implementation Framework – Air Quality Figure 18: Total NOx emissions timeseries by sector for Poland Figure 19: Total PM2.5 emissions timeseries by sector for Poland Poland failed to meet its emission reduction commitments for 2010 for NMVOC and NOX. The European Commission’s review of the implementation of the NECD (2016/2284) in each Member State85 concluded that there was a high risk of Poland failing to meeting its emission reduction commitments in either 2020 or 2030 for all pollutants other than SO2 and PM2.5 where the risk was judged as medium for 2020 (based on a review of Poland’s NAPCP and emissions inventories and projections). TRENDS BY KEY SOURCE SECTOR ENERGY INDUSTRIES Public heat and power generation in Poland is heavily dependent on coal. The IIR shows that the share of solid fuel consumption, mainly hard coal and lignite, in this sector was 94% in 1990, falling to 81% in 2019, with increases in gaseous and biomass sources accounting for the difference. Emissions of SO2 and PM2.5 from the sector have fallen dramatically over the same period, indicating an increasing use of emissions control techniques. Nevertheless, the energy industries sector remains the highest emitting source for SO2 and the second highest for NOX. 65 According to the International Energy Agency (IEA), the residential and industrial sectors account for the largest shares of energy consumption at 29% and 30% respectively, followed by the transport (24%) and commercial (17%) sectors.107. Figure 20: Primary energy consumption [Mtoe] by source in Poland 1973 – 2015107 TRANSPORT Emissions from the transport sector in Poland are dominated by road transport. Since 1990, as low sulphur fuels have become available and emission control technology has been introduced, emissions of sulphur dioxide and NMVOC have shown a downward trend. However, these reductions have been offset by a very large increase in passenger cars, and since 2005, diesel cars in particular. Fuel consumption for petrol and diesel in 1990 was 3,032 and 2,747kt respectively, rising to 4,414 and 13,900kt in 2019. As a result, emissions of NOX from the transport sector have risen since 1990. Poland has the highest proportion of cars over 20 years old or more (37%) of any EU member state108. The average age of cars in Poland is 14.1 years, compared to an EU average of 11.5109. Poland also has some of the oldest buses, with an average age of 15.6 years, compared to an EU average of 11.7 years. Eurostat figures also show that Poland has a higher percentage of sales for alternatively-fueled cars than other EU member states110. However, this is likely to be accounted for by the sale of LPG/CNG fueled vehicles which has been facilitated by the development of a fueling network for CNG, and the introduction in 2018 of a zero-excise rate for LNG and CNG105. Across the EU, the control of emissions from road transport, a significant driver of air quality in urban areas, has relied on tightening emission standards for new vehicles. An older vehicle fleet, and the proportion of cars over 20 years old, means that newer, cleaner vehicles are being introduced into 107 IEA. 2017. „Energy Policies of IEA Countries – Poland – 2016 Review.â€? International Energy Agency, France. 108 https://ec.europa.eu/eurostat/statistics- explained/index.php?title=Passenger_cars_in_the_EU#Highest_share_of_passenger_cars_over_20_years_old_in_Poland 109 https://www.acea.auto/figure/average-age-of-eu-vehicle-fleet-by-country/ 110 https://ec.europa.eu/eurostat/statistics- explained/index.php?title=File:New_passenger_cars_with_alternative_fuel_engine,_2017- 2019_(%25_of_new_passenger_cars)_v2.png 66 Sustainable Cities Implementation Framework – Air Quality Poland far more slowly than is the case for other EU member states. Thus, the delivery of air quality improvements will also be far slower than the European norm. OTHER FUEL COMBUSTION SOURCES (INCLUDING RESIDENTIAL) The “other sourcesâ€? sector includes commercial and residential fuel combustion, fuel combustion in the agriculture, forestry and fisheries industries, and non-road mobile machinery emissions. Energy consumption in the sector is dominated by residential sources, which in turn is dominated by hard coal consumption. Coal used for household heating makes up one-third of total energy consumption in the residential sector (IEA, 2017). The residential sector is the largest consumer of heat, accounting for 71% of total heat consumption in Poland (IEA, 2017). According to Poland’s IIR, the general level of coal use in the residential sector has remained largely unchanged since 1990, with 272,689 TJ consumed in 1990 falling to 214,825 TJ in 2019. Over this period, natural gas consumption has increased slightly (122,204 TJ to 152,348 TJ) and wood fuel has increased significantly, from 38,875 TJ to 102,600 TJ. Thus, domestic and residential heating is heavily reliant on solid fuel use, a trend which shows little sign of changing. Figure 21: Heat Production [Mtoe] by Source in Poland in the Period 1973 – 2015 111 The use of polluting fuels in unregulated appliances in homes, along with burning of waste products in household boilers and stoves is responsible for the exceedances of air quality standards for PM 2.5, PM10, and BaP in Poland. These impacts are due to four major factors: ï‚· poor quality of fuels ï‚· ineffective combustion in old boilers and stoves, with average ages of 10 years and over 24 years, respectively ï‚· pollutants generated during combustion are not captured by any control devices ï‚· pollutants are emitted to the air through low height stacks, therefore they concentrate where they originate, i.e. typically in densely populated built-in housing areas112. 111 IEA. 2017. „Energy Policies of IEA Countries – Poland – 2016 Review.â€? International Energy Agency, France. 112 Sówka, Kobus, et al. 2017. „Characteristics of selected elements of the air quality management system in urban areas in Poland.â€? E3S Web of Conferences 22, 00165. https://www.e3s- conferences.org/articles/e3sconf/pdf/2017/10/e3sconf_asee2017_00165.pdf 67 AIR QUALITY TRENDS Air quality in Poland continues to give cause for concern. The EEA estimated that in 2019 about 46,300 premature deaths were attributable to fine particulate matter exposure, 1,500 to ozone and 1,900 to NO2113. Poland has some of the most polluted cities in the EU with some of the highest concentrations of PM10 and PM2.5.114 The EEA ranked European cities from the cleanest city to the most polluted, on the basis of average levels of fine particulate matter (PM2.5) over the past two calendar years (2019-2020), and cities in Poland are some of the lowest ranking cities. 115 The EEA106 has compiled maps and graphs illustrating air quality in Poland; these are reproduced in Figure 22, Figure 23 and Figure 24. The maps on the left show the air quality monitoring stations in Poland and concentrations of pollutants measured at each station. The graphs on the right present trends in annual mean concentrations since 2010 by station type. For PM10, the 90.41 percentile of annual measurements is presented, which is used to approximate compliance with the daily limit value. The daily mean limit value for PM10 was consistently exceeded across Poland, with the highest levels measured in the south and around Krakow. By contrast, the annual mean limit value for NO2 was generally complied with across Poland, with the exception of urban monitoring sites in Wroclaw, Czestochowa, Rzeszow and Warsaw. The target level for BaP was exceeded at most monitoring sites. Accompanying time series graphs indicate generally declining concentrations of PM10 and BaP since 2010, while NO2 concentrations were more stable with fewer identifiable trends. Figure 22: PM10 measurement data and measurement locations in Poland 113 https://www.eea.europa.eu/themes/air/country-fact-sheets/2021-country-fact-sheets/poland 114 EEA. 2020. Air quality in Europe – 2020 report. ISSN 1977-8449. file:///C:/Users/lucas/AppData/Local/Temp/Air%20quality%20in%20Europe%20-%202020%20report-1.pdf 115 EEA. 2021. European city air quality viewer. https://www.eea.europa.eu/themes/air/urban-air-quality/european-city- air-quality-viewer 68 Sustainable Cities Implementation Framework – Air Quality Figure 23: NO2 measurement data and measurement locations in Poland Figure 24: BaP measurement data and measurement locations in Poland In 2017, Limit Values were breached in most of Poland’s 46 air quality zones: for particulate matter (PM10 in 34 zones, and for PM2.5 in 19 zones), for NO2 in four zones (Warszawska, Krakowska, WrocÅ‚awska and GórnoÅ›lÄ…ska) and for SO2 in one zone. Poland was referred to the Court of Justice of the EU by the European Commission in 2015 over continued exceedance of the daily mean limit value for PM10, and was ruled to be in breach of its obligations under the AAQD in 2018. Moreover, benzo[a]pyrene (BaP) Target Values were continuously being exceeded throughout Polish territory; BaP is strongly associated with poorly controlled combustion, such as domestic coal burning. Table 9 is taken from the EEA’s fact sheet for Poland, published in 2020 and drawing on data up to 2018, and shows the proportion of the population living in zones where the air quality limit values and targets are exceeded. 69 Table 9: Percentage of urban population in Poland exposed to concentrations above EU standards116 Pollutant 2015 2016 2017 2018 2019 BaP Annual mean 99.6 100.0 100.0 100.0 93.5 NO2 Annual mean 1.4 1.2 1.2 1.5 1.5 O3 Percentile 93.15 37.6 1.6 11.2 23.4 5.8 PM2.5 Annual mean 52.8 50.9 52.1 50.5 30.5 Annual mean 57.8 51.7 58.7 56.1 44.6 PM10 Percentile 90.41 80.6 59.0 70.8 82.3 36.4 As noted above, Poland is divided into 46 zones and agglomerations, for the purposes of assessment against EU Limit and Target Values: 12 agglomerations, 18 cities with a population of more than 100,000, and 16 further areas. The annual assessment is based on fixed-point monitoring, supplemented by modelling (CAMx 6.30 model). Poland reports data from 279 monitoring sites to the European Environment Agency. The operation of the monitoring network is the responsibility of Voivodeship Inspectorates of Environmental Protection (WIOS), and is organized at a regional rather than a city level. However, monitoring activities are coordinated by the national Inspectorate of Environmental Protection. While the figures in Table 10 indicate an extensive national monitoring network, the number of monitors focused on the key health pollutants (such as PM2.5 and NO2) in urban centers remains relatively limited (see box below). More could be done at a city level to develop local sensor networks as a means of informing the public about air pollution and how it varies in their area both temporally and spatially. Table 10: Monitoring stations used to report data to the European Environment Agency Pollutant Traffic Urban/suburban Industrial Rural Total background PM10 15 205 7 17 244 PM2.5 10 104 1 8 123 NO2 16 100 3 23 142 BaP 2 144 4 7 157 Monitoring data, both archived and near-real-time, is available from the Inspectorate of Environmental Protection, and displayed via their air quality portal: http://powietrze.gios.gov.pl/pjp/current. Although information is publicly disseminated online in real- time, a transition to a more health-based approach to the Polish Air Quality Index (PAQI) would be helpful to raise awareness and ensure appropriate actions are taken by susceptible members of the public. Furthermore, given the adverse impacts of PM2.5 in health outcomes, air quality alerts should eventually include PM2.5. Box 7: City Scale Monitoring: Poland There are only two continuous monitoring sites in Katowice, neither in the city center, with eight covering the “Upper Silesian Agglomerationâ€? of which Katowice is part. 116 EEA. 2021, Air pollution country fact sheet – Poland https://www.eea.europa.eu/themes/air/country-fact-sheets/2021-country-fact-sheets/poland 70 Sustainable Cities Implementation Framework – Air Quality Poznan has five sites, all of which are classified as background. Warsaw has eight sites (one solely monitoring ozone), only one of which is classified as a traffic site Campaign-style studies using low costs sensors, which provide extensive information on a small area basis for a short time period, have been undertaken in Poland, such as in Krakow in Spring 2020117. However, more could be done to bring such work into the public realm and ensure it is coordinated with both policy implementation and public information campaigns. In December 2020, Warsaw City Hall signed a contract for supply of a comprehensive system for monitoring air quality 118 . The system will make use of continuous monitoring sensors at 165 locations across the city and 17 partner municipalities to measure levels of PM10, PM2.5, PM1, NO2 and ozone. Data will be publicly accessible via a free online and mobile platform. CURRENT STATUS AND GAP ANALYSES POLICY AND LEGISLATION Polish air quality legislation, built around the transposition of EU legislation, is complemented by national strategies and programmes, which jointly provide the regulatory basis for air quality management at national, regional (voivodeship) and local levels. The Environment Protection Law, enacted in April of 2001, regulates issues related to air quality management in Poland. The Law transposes the provisions of the AAQD. National strategies determine the goals of the country’s policy, and although without legal force, they set the directions at a national level for air quality management in Poland. Two strategies specifically address air pollution: 1. National Air Quality Plan (NAQP) The foundation of current air quality management in Poland is the NAQP of 2015, which sets goals and directions for actions that should be included in all Air Quality Plans prepared at the sub-national level. The introduction of NAQP is a key step in air quality management development in Poland and represents the first time that the strategic actions for air quality improvement across the country were discussed in a comprehensive way and in one overarching document. A key challenge identified by the NAQP is to decrease the concentrations of PM10, PM2.5, BaP, NO2 and O3 to levels not exceeding air quality standards. According to the NAQP, residential heating (by annual air quality assessments in Voivodeships) is the prevailing reason for exceedances of air quality standards throughout most of the country: in 2013 this sector was responsible for 88%, 87% and 98% of exceedances of PM10, PM2.5 and BaP, respectively. 2. Clean Air Programme (CAP) In response to a period of numerous and severe exceedances of air quality standards, the Council of Ministers adopted a Clean Air Programme in 2017, with the Plenipotentiary of the Prime Minister for the Clean Air Programme appointed in 2018, with the task 117 Danek and ZarÄ™ba. 2021. “The Use of Public Data from Low-Cost Sensors for the Geospatial Analysis of Air Pollution from Solid Fuel Heating during the COVID-19 Pandemic Spring Period in Krakow, Poland.â€? Sensors 2021, 21(15), 5208; https://doi.org/10.3390/s21155208 118 https://airly.org/en/warsaw-is-the-european-capital-with-the-largest-air-quality-monitoring-network/?s=09 71 of implementing the CAP. The Plenipotentiary was also appointed as the head of the NAQP Steering Committee, thus broadening the scope of the Committee’s activities to also cover the CAP. The CAP consists of 15 detailed recommendations to implement the NAQP. Accomplishments with respect to implementation of the recommendations of the CAP have been mixed. Notwithstanding, the government has made notable achievements in passing new legislation and strengthening support for programs to address air pollution primarily from the residential and transport sectors. Four of the key recommendation areas in the CAP that address air pollution from the residential and transport sectors as summarised below: 1. Technical requirements for solid fuel boilers - in 2017 the Government adopted regulations which introduced, for the first time, technical requirements for small-scale solid fuel boilers used in the residential and service sectors. The regulation prohibits the sale of the more polluting no-class, class 3 and class 4 boilers effective from July 2018. Furthermore, only class 5 boilers meeting more stringent emission requirements may be used in new installations. The class 5 boilers have similar emission requirements as stated in the EC Eco-design Regulation, with the exclusion of NOX. The following types of installations are exempt from the requirements of the Eco-design Regulation: (i) boilers generating heat exclusively for providing hot drinking or sanitary water; (ii) boilers for heating and distributing gaseous heat transfer media such as water vapor or air; (iii) solid fuel cogeneration boilers with a maximum electrical capacity of 50KW or more; and (iv) non-woody biomass boilers. It will be important to address legislative gaps that could allow boiler manufacturers to bypass the requirements of the law, in particular in relation to exempt installations (e.g. by selling no-class coal boilers originally designed for heating, as hot water heaters). Furthermore, penalties to deter such behaviours could be put in place and enforced. 2. Regulations on solid fuel quality standards – Following amendment of the Act on the fuel quality monitoring and control system (which previously addressed liquid and gaseous fuels only) to include solid fuels used by households and small consumers, the Government adopted a regulation on quality requirements for solid fuels in 2018. The new regulation sets standards including maximum ash, sulphur and moisture contents, minimum calorific value for coal, briquettes, pellets, coke and coal slack. The regulation prohibits the sale of low-quality coal fines (grain size of 1 mm-31.5 mm) effective June 2020. However, enforcing the ban in households may be challenging and the Government will need to take strict measures, including incentives to enforce the ban. While the fuel quality standards are clearly a positive development, there is room to make them more stringent. For example, the new regulations specify up to 1.7% sulfur content for coal use for small consumers. By comparison, in some other coal-consuming countries, sulfur content for all consumers is: Czech Republic (0.42-0.43%); Turkey (0.8-1.0%); and Germany (0.45-1.8%)119. The Polish Government could take steps to further reduce the sulfur content of solid fuel in the short- to medium-term. 3. Support for replacement of old boilers and improvement of energy efficiency of residential buildings. The Government adopted a Clean Air Priority Programme in June 2018 (in addition to the CAP), aimed at improving energy efficiency and controlling air emissions from existing and newly built single-family buildings by co-financing replacement of boilers, changes to cleaner fuels and thermal insulation through subsidies, preferential loans and combinations thereof, as well as tax incentives related to thermo-modernization. The Programme, with a budget of PLN 103 billion (€22.6 billion), 119 Euracoal, 2021. Country Profiles: https://euracoal.eu/info/country-profiles/ 72 Sustainable Cities Implementation Framework – Air Quality will be implemented over a 10-year period (2018-2029), by the National Environmental Protection and Water Management Fund in collaboration with provincial funds for environmental protection and water management. Recognizing the scale of needs, the Government anticipates EU funding for implementation of the Programme in addition to local funding. 4. Incentives for low-emission transport. The CAP calls for the use of tax mechanisms, including low excise duty rates for hybrid cars and exemption of electric cars from excise taxes, to introduce low- emission transport. In 2018, the Government enacted a law on electromobility and alternative fuels, to implement the national Electromobility Development Plan, launched in 2017. The Plan envisages 1 million electric cars in Poland by 2025 and provides for a system of incentives including excise exemptions for electric cars and a temporary excise exemption for plug-in hybrids; exemption of electric cars and plug-in hybrids from parking fees and permitting them to drive on bus lanes; and larger depreciation write-offs for electric cars and hybrids compared to regular vehicles. The law introduces the creation of low-emission zones by municipal governments in densely built-up areas. Implementation of the law provides potential opportunities for economic development, in addition to environmental improvements. Given the relatively old age of Poland’s vehicle fleet and that people of lower economic status are more likely to drive older vehicles, the Government could consider understanding the distributional impacts of implementing low-emission initiatives. Despite this framework, the European Commission’s 2019 EIR review concluded that “no progress has been made on improving air quality since the 2017 EIRâ€? and that “air quality in Poland continues to give cause for severe concernâ€?. The review considered the measures set out in the CAP but concluded that significant gaps remain. For example, while there are financial incentives for households to replace substandard boilers, there is nothing to stop their continued use. Priorities identified include: ï‚· Take, in the context of developing an adequate National Air Pollution Control Programme (NAPCP), actions towards reducing the main emission sources - and meet all air quality standards. ï‚· Cut particulate matter (PM2.5 and PM10) and benzo(a)pyrene emissions and concentrations faster, connecting houses to district heating and providing financial support for replacing substandard domestic boilers by low-emission heaters and those using renewable energies. ï‚· Cut nitrogen oxide (NOx) emissions and nitrogen dioxide (NO2) concentrations faster by reducing transport emissions, especially by establishing urban vehicle access restrictions, a tax system linked to emission levels, etc. ï‚· Reduce the use of coal for domestic heating in order to limit air pollutants emissions, for instance building on the “Coal regions in transitionâ€? initiative. Some further action is being taken at the regional and city level as set out in the box below: 73 Box 8: Regional and city-level actions to improve air quality in Poland: Katowize, Poznan, and Warsaw Katowice The Silesian Regional Assembly passed an “anti-smogâ€? resolution in 2017 (Resolution No V/36/1/2017) which goes further than the national regulations on boilers and solid fuel in that it sets out a timescale for the replacement of older boilers and bans the use of brown coal, coal with a grain content of 0-3 mm above 15%, and biomass with a moisture content of more than 20% from 2017. However, the replacement timescale only starts in 2022 and runs through to 2028120 Katowice also has a short term, action plan, based on trigger levels of air pollution. While the plan includes “intensified inspections of the Municipal Police in Katowice aimed at proper waste management and the burning of appropriate solid fuelsâ€? there is little by way of concrete actions. Katowice maintains an online information system about air quality, including social media channels, and is participating in the AWAIR Interreg programme: https://www.interreg- central.eu/Content.Node/AWAIR/AWAIR.html Poznan The Wielkopolska (Greater Poland) Voivodeship adopted a similar “anti -smogâ€? resolution in December 2017 (Resolution No. XXXIX / 942/17), phasing out older, solid fuel domestic stoves and boilers in favor of those meeting the EU eco-design standards. This includes prohibiting the use of non-compliant stoves on high pollution days (i.e. those when the EU Limit Value for PM10 is exceeded), which occurred, for example, on 17 November and 27 and 28 December 2021121. Warsaw The Masovian Voivodeship, where Warsaw is located, has adopted an air pollution control program with the explicit aim of reducing emission for key pollutants, in order to meet the EU Limit and Target Values: ï‚· 44% for PM10 ï‚· 57% for PM2.5 ï‚· 69% for benzo(and)pyrene ï‚· 27% for dioxide nitrogen The plan includes a “Clean Transportâ€? Zone to encourage the use of low emission vehicles, as well as a transport emissions monitoring system, public transport upgrades and the expansion of the tram network. These are in addition to the regional program for the replacement of older stoves and boilers, which is along the same lines as the program for Silesia. In 2020, the city authorities committed to the phase out of coal fired heating by the end of 2023, with a ban on the use of fireplaces by the end of 2023122. Warsaw is also developing a network of 165 small sensors to help characterize air pollution across the city and surrounding communities and, as part of the Masovian Voivodship’s Air Protection Program, is investigating setting up a low emission zone in the city 123. 120 See: https://www.katowice.eu/dla-mieszka%C5%84ca/miejskie-centrum-energii/powietrze/uchwa%C5%82a- antysmogowa 121 See: https://www.poznan.pl/mim/wos/news/zakaz-ogrzewania-domow-kominkami-i-piecami-dla-posiadajacych-inne- ekologiczne-zrodlo-ciepla,174721.html 122 See: https://en.um.warszawa.pl/-/warsaw-making-a-commitment-to-improve-air-quality 123 See: https://eko.um.warszawa.pl/-/program-ochrony-powietrza 74 Sustainable Cities Implementation Framework – Air Quality INSTITUTIONS AND CAPACITIES Duties and responsibilities for addressing air quality are distributed across the Polish governance framework, with an emphasis on decentralization: ï‚· Central Government: overall economic policy and national legislative structure. Ultimate responsibility for meeting the requirements of EU legislation and other international obligations. Development and adoption of National Air Quality Plan (NAQP) and National Air Pollution Control Programme (NAPCP). ï‚· Inspectorate of Environmental Protection (IOS): industrial pollution control, coordination of environmental monitoring (including air quality). ï‚· Voivodeship (regional) Inspectorates of Environmental Protection: installation and operation of air quality monitoring networks. ï‚· Voivodeship authorities: development of regional air quality plans. Spatial and development planning. A World Bank sponsored report in 2019124 was critical of the administrative structure for delivering air quality improvements in Poland and in particular: ï‚· The lack of clear and uniform guidance for sub-national authorities in the delivery of air quality management, ï‚· Differing capacities and resources for air quality management across the Voivodeships, ï‚· A lack of consistency in the implementation of laws and regulations relating to air quality across Poland, and ï‚· A lack of clarity around the roles and responsibilities of the Environment Minister and the Plenipotentiary for Clean Air, appointed by, and responsible to the Prime Minister. Coordination and Implementation The basic elements in the urban air quality management system in Poland are constantly developed in compliance with (or aiming at compliance with) requirements referred to in applicable legal regulations. However, legal and coordination issues at the level of implementation of the area development policy should be improved. 125Currently, the biggest difficulties in activities aiming at protection of ambient air are delegation of tasks without legal support at the national level, especially in case of emission requirements for combustion of fuels of power of up to 1 MW and admission of high emission fuels on the market. Voivodeship governments, which are responsible for preparation of ambient air protection programs, do not have any coercive means or financial support for communes. Works on coordination of those activities should cover issues within the scope of the structure of planning documents including mainly: ambient air protection programmes, spatial developments plans in communes and Voivodeships, low emission economy plans, plans of sustainable development of public transport, plans of providing heat, electric power and gas fuels to communes, acts of regional parliaments, introducing limitations based on the Environmental 124World Bank. 2019. Air Quality Management in Poland. 125 Sówka, Kobus, et al. 2017. „Characteristics of selected elements of the air quality management system in urban areas in Poland.â€? E3S Web of Conferences 22, 00165. https://www.e3s- conferences.org/articles/e3sconf/pdf/2017/10/e3sconf_asee2017_00165.pdf 75 Protection Law and strategies of Voivodeship development. The structure of coordination of the development policy should be made simpler and the Voivodeship spatial development plan should be integrated with its development strategy. Then, strategic aims concerning air protection would gain a territorial dimension at the stage of their definition.126 FINANCING Adequate funding is an important factor in ensuring effectiveness of implementing air quality planning and management. Understanding criteria for prioritizing activities to be funded and ensuring that environmental expenditures are aligned with air quality planning priorities are important for enhancing implementation effectiveness of AQPs. In some countries, public environmental expenditure reviews have been used to inform priority setting for air quality management and could be a valuable tool at the regional level, particularly in the voivodeships where the cost of health damage from ambient air pollution is highest. Poland collects fees based on emission registries, and administrative fines as penalties for exceeding permit emission limits. Payments are made by businesses and institutions which emit various pollutants, from both stationary and mobile sources. However, the residential sector is the leading contributor to PM emissions. Funding is now in place for the replacement of older or substandard boilers and heating systems. It is not clear whether this funding is being applied equally in all Voivodeships, nor whether it is being targeted at areas of greatest need. The funding is being actively promoted in Katowice, for example127 but it is not clear whether this level of accessibility or funding is being applied in other cities. As noted earlier, Poland has the highest proportion of cars over 20 years old, and also one of the oldest bus fleets. While the Clean Air Plan includes incentives for low emission transport, and Warsaw is introducing a Clean Transport Zone, it is not clear how effective these are in terms of increasing the update of cleaner vehicles and, crucially, removing older, more polluting vehicles from the fleet. While domestic emissions are currently a key driver for poor air quality, increasing control of this sector will mean that transport emissions become more prominent, and so opportunities to improve fleet performance need to be taken in the near term. RECOMMENDATIONS The recommendations build on, and in some cases reiterate, those made in earlier studies, most notably the European Commission’s 2019 EIR and the World Bank’s report on Air Quality Management in Poland. There are three key areas: Governance The sources of air pollution in Poland will be challenging to shift, since they require multiple actors — residential heating, industry, and the transport sector more broadly — to play their part. Due to the sources of air pollution being spread across the population and across areas, it will take multiple 126 Sówka, Kobus, et al. 2017. „Characteristics of selected elements of the air quality management system in urban areas in Poland.â€? E3S Web of Conferences 22, 00165. https://www.e3s- conferences.org/articles/e3sconf/pdf/2017/10/e3sconf_asee2017_00165.pdf 127 See: https://www.katowice.eu/dla-mieszka%C5%84ca/miejskie-centrum-energii/wymiana-ogrzewania- w%C4%99glowego-budynki-jednorodzinne 76 Sustainable Cities Implementation Framework – Air Quality actors to address and reduce pollution sources, including millions of homes that need upgrading, the authorities helping them with these investments, regulating actions and enforcing these regulations, and supply side actors. All of this will require a strong governance process, including: ï‚· The allocation of roles and responsibilities at the national, regional and city scales, and how each relate to and support each other, needs to be clarified, with some urgency. ï‚· Greater efforts are needed in the unification of air quality investigation, reporting and action planning across the regions, while at the same time encouraging the development of local actions to address particular local priorities. ï‚· Greater support is needed at the local level for action planning, including the provision of tools and expertise to characterize the issue and prioritize action. Domestic emissions Putting in place and enforcing regulations across all Voivodeships on heating technologies will be a significant step forward in addressing domestic heating emissions. Owners of single-family buildings need financial and advisory help in shifting their heating technologies and retrofitting their buildings. Building retrofit and upgrading a boiler requires substantial upfront costs and the payment period for these investments can be long. Supporting households financially and through advice on the investments needed will be critical, in particular for poorer households. Seeing this challenge, the Government launched the Clean Air Priority Programme (CAPP) and Stop Smog Programme which, together with tax credits, aim to ease the burden on households of making these investments. Key policies should include: ï‚· The phase out of coal as a domestic heating fuel and the uptake of non-combustion-based heating system needs to be accelerated. ï‚· This will require legislation, education and awareness raising, and funding to implement. Transport Cities should identify hot-spots, about which knowledge is not yet sufficient, through regular monitoring and introduce targeted measures in these areas. One potential way to obtain this information would be an increase in street-level monitoring (a modelling approach could also be used but would require a detail emissions inventory and characterization of domestic sources, which are notoriously difficult to estimate). Pollution linked to transport can be very geographically concentrated, so specialized monitoring approaches are needed. With such data at hand, decision- makers could introduce targeted policies on air pollution, such as traffic zones, new routings, or enhanced public transport. Continuing the expansion of electric mobility is a step in the right direction. Without appropriate interventions, the high growth rate of vehicles across Poland is likely to increase the share of air pollution coming from the transport sector, especially affecting urban populations. Measures should include: ï‚· Increase penetration of cleaner and low emission vehicles into fleet, targeting vehicles over 20 years old. ï‚· The current bus fleet need to be modernized and replaced with electric or low emission alternatives, in order to provide a viable alternative to private car use. 77 ROMANIA URBAN CONTEXT BASIC DEMOGRAPHIC AND SPATIAL INDICATORS128 POPULATION SPACE Population: 19 286 120 inhabitants (2020) Area: 238,400 km2 Urban Population: 54% Settlement area: 528.4 m2 / capita 129 Pop. in Urban Agglomeration > 1 mil. (% total): 9% Population Density: 84 inhabitants / km2 Population Change: -2.8% (2012-2018) Built-up area change: 44.6% (2012-2018) Population Growth Rate: -0.47% (2012-2018) Land Consumption Rate: 6% (2012-2018) EEA CITY AIR QUALITY RANKING ON THE LEVEL OF PM2.5 MEAN CONCENTRATIONS OVER 2019 & 2020130,131 CITY BUCHAREST CONSTANÈšA SIBIU EU ranking 263/323 No data No data Fine particulate matter (PM2.5) in 16.4 No data No data μg/m3 City’s population 1 877 541 (9.73%) 283 872 (1.47%)132 169 056 (0.88%)133 (National %) Poor air quality continues to be a problem in Romania, especially in urban settings. For 2019 the EEA estimated that about 21,500 premature deaths were attributable to concentrations of fine particulate matter, 640 to ozone and 3,660 to nitrogen dioxide53. The main sources of air pollution come from the transport and energy sectors, in particular fossil fuels and the use of domestic solid fuel in households. At the same time, serious and structural shortcomings have been identified in the air-quality data reported by the Romanian monitoring network, meaning that the situation could potentially be worse than reported to the EU and researchers.134 128 Data source: World Bank Data (population and geography), Eurostat (land consumption) 129 EU-27 average: 703.4 m2 / capita 130 EEA. 2021. “European city air quality viewer.â€? https://www.eea.europa.eu/themes/air/urban-air-quality/european-city- air-quality-viewer 131 Cities marked as “No dataâ€? have not been included in the EEA “European city air quality viewerâ€? for one of the three reasons below: ï‚· The city does not have urban or suburban air quality monitoring stations. ï‚· The urban and/or suburban air quality monitoring stations in the city have not reported data covering 75% of the days in the year. ï‚· The city is not included in the database of cities established under the European Commission’s Urban Audit. 132 Primăria Municipiului ConstanÅ£a. 2021. http://www.primaria-constanta.ro/ 133 Sibiu Hermannstadt Turism. 2021. https://turism.sibiu.ro/en 134 European Commission. 2019. „The Environmental Implementation Review 2019 – Country Report Romaniaâ€? - https://ec.europa.eu/environment/eir/pdf/report_ro_en.pdf 78 Sustainable Cities Implementation Framework – Air Quality This chapter examines the air quality situation in Romania, while deep-diving into three urban settings: Bucharest, ConstanÈ›a and Sibiu. It examines the sources and types of pollutants that are present at national and urban settings in Romania. Furthermore, it analyzes the challenges and trends of the pollutants and assesses the gaps and impacts through three areas: Policy & Legislation, Institutions & Capacity, and Financing. Finally, recommendations for air pollution prevention, reduction and abatement are presented. EMISSION TRENDS Romania’s IIR for 2021135 sets out trends in pollutant emissions by sector since 1990. Key emissions data are displayed in Table 11. The period 1990-2019 has seen a sharp decline in emissions of SOx as well as a halving of NOx and ammonia emissions. The IIR attributes these reductions to uptake of low- sulphur fuels and deployment of emissions abatement systems in large combustion plant (LCPs). NMVOC emissions have declined by 29%. In contrast, the same period has seen an increase in PM10 and PM2.5 emissions of 16% and 45% respectively. Table 11: Total pollutant emissions for Romania, 1990-2019 Pollutant Emissions (kt) 1990 2019 Reduction SOx 819 99 88% NOx 429 217 49% NMVOC 326 230 29% NH3 366 178 51% PM10 132 153 16% increase PM2.5 77 112 45% increase Data from the EEA’s fact sheet for Romania136 indicates that both NOx (Figure 25) and PM2.5 emissions (Figure 26) have declined slightly since 2010. Road transport is the major source of NOx emissions (39%), with sizable contributions from energy production (15%) and manufacturing and extractive industry (13%). In 2019, residential, commercial and institutional emissions accounted for 82% of total PM2.5 emissions, with manufacturing and extractive industries the source of a further 9%. Overall, the relative contributions of different sectors to total PM2.5 and NOx emissions has remained stable since 2010. Note: figures are displayed with divisions within sectors to represent unlabeled sub-sectors; for example, transport is divided into road and non-road transport. 135 Ministry of Environment, Water and Forests. 2021. Romania’s Informative Inventory Report 2021. 136 EEA. 2021. Romania – Air pollution country fact sheet. https://www.eea.europa.eu/themes/air/country-fact- sheets/2021-country-fact-sheets/romania 79 Figure 25: Total NOx emissions timeseries by sector for Romania Figure 26: Total PM2.5 emissions timeseries by sector for Romania TRENDS BY KEY SOURCE SECTOR ENERGY INDUSTRIES Total energy consumption in Romania has declined from 1990 to 2019 (Figure 27). Despite this overall decrease, Romania is still reliant on fossil fuels, with oil, natural gas and coal accounting for 29%, 28% and 15% of energy supply in 2019. Reliance on oil has remained fairly stable since 2000, while natural gas and coal use have decreased. Simultaneously, biofuels, nuclear energy, and wind, solar, and other renewables have increased, and together account for 24% of energy supply in 2019. 80 Sustainable Cities Implementation Framework – Air Quality Figure 27: Total energy supply in Romania by energy source, 1990-2019137 TRANSPORT As indicated in Figure 25, transport is the predominant source of NOx emissions in Romania. Data from Romania’s IIR (Figure 28) indicates that the number of vehicles has quadrupled between 1990 and 2019. This increase has been driven most prominently by a rise in the number of passenger diesel cars, which were a minor fraction of the overall fleet in 1990 but constitute a third of all vehicles in 2019. The number of petrol and LPG passenger cars has seen a steady increase over this period, as has the number of diesel LDVs. The number of diesel HDVs and buses has also increased gradually since 2005. Figure 28: Number of vehicles and fleet composition in Romania, 1990-2019 135 137 IEA. 2019. Country profile: Romania. https://www.iea.org/countries/romania 81 These trends are consistent with IIR data on fuel consumption (Figure 29). Following fluctuating levels in the 1990s, total fuel consumption in Romania has steadily risen since 1999, driven by increasing diesel consumption. Petrol use has declined slightly over this period, and LPG continues to form a minor fraction of the overall fuel mix. Passenger cars in Romania had an average age of 16.5 years in 2019, compared with a European average of 11.5 years84. The passenger car fleet is still dominated by petrol (55.3%) and diesel (43.3%) vehicles, with battery and hybrid electric cars / plug-in hybrids accounting for only 0.2% of the fleet. Romania’s passenger vehicle fleet is composed of older petrol and diesel vehicles, with limited electric and hybrid vehicle penetration. Conventionally fueled passenger vehicles, particularly older ones, are associated with increased NOx and PM emissions in urban areas. Figure 29: Fuel consumption for road transport by fuel type in Romania, 1990-2019 135 OTHER FUEL COMBUSTION SOURCES (INCLUDING RESIDENTIAL) Figure 26 identifies residential, commercial and institutional energy consumption as the principal source of PM2.5 emissions in Romania. Figure 30 provides a breakdown of fuel consumption in residential heating since 1990. Total fuel consumption increased up until 2005, after which it has been largely stable. Solid fuel use declined sharply until around 1998 and has remained a minor fraction of the fuel mix thereafter. Gaseous fuel use increased slightly and has remained stable since 2003. Use of biomass in residential heating has increased consistently throughout the period. In 2019, gaseous fuels and biomass both account for approximately half of total fuel use. 82 Sustainable Cities Implementation Framework – Air Quality Figure 30: Fuel consumption within residential heating in Romania, 1990-2019 135 Figure 31 displays PM10 emissions from residential heating to different fuel types. Since 1990, PM10 residential heating emissions have been largely associated with wood combustion. In terms of NOx emissions from residential heating (Figure 32), gas and wood combustion have been the primary sources, although their relative contributions have fluctuated between 1990-2019. In 2019, gas and wood each accounted for approximately half of NOx emissions from residential heating. Figure 31: PM10 emissions by residential heating fuel in Romania, 2000-2019 135 83 Figure 32: NOx emissions by residential heating fuel in Romania, 2000-2019 135 AIR QUALITY TRENDS An estimated 25,400 deaths in Romania in 2015 were attributable to concentrations of fine particulate matter, and a further 1,300 attributable to NO2 exposure138. As of January 2022, Romania has failed to produce an NAPCP in line with its obligations under the NECD. The Environmental Implementation Review for Romania highlights that there is a risk that the issue of air pollution is being underestimated due to inadequate monitoring in the country138. The EEA has compiled maps and graphs of air quality in Romania in 2019136; these are displayed in Figure 33, Figure 34 and Figure 35. The maps on the left show the locations of monitoring stations in Romania and the concentrations of pollutants measured at each station. The graphs on the right show trends in annual mean concentrations since 2010 by station type. For PM10, the 90.41 percentile of annual measurements is presented, which is used to approximate compliance with the daily limit value. The daily mean limit value for PM10 was exceeded at eight locations in 2019, including two in Bucharest. NO2 concentrations exceeded the annual mean limit value at eight locations, including in Bucharest. Only two sites measure BaP in Romania, both of which recorded levels below the target value in 2019. The accompanying concentration time series show that since 2010, PM10 levels have decreased slightly, while NO2 levels have remained fairly constant. There is insufficient monitoring data to draw conclusions on temporal trends in BaP concentrations. 138 EC. 2019. The Environmental Implementation Review 2019: Country Report Romania. https://ec.europa.eu/environment/eir/pdf/report_ro_en.pdf 84 Sustainable Cities Implementation Framework – Air Quality Figure 33: PM10 measurement data and measurement locations in Romania Figure 34: NO2 measurement data and measurement locations in Romania 85 Figure 35: BaP measurement data and measurement locations in Romania Estimated percentages of the urban population in Romania living in areas exposed to pollutant concentrations in breach of EU limit/target values, obtained from the EEA country profile, are displayed in Table 12. Half the urban population was estimated as being exposed to non-compliant concentrations of BaP in 2019, with 41% exposed to PM10 levels above the annual mean limit value. A quarter of the population was exposed to exceedances of the PM2.5 limit value, while a much smaller fraction was exposed to levels breaching the annual mean limit value for NO2 (2.5%). Table 12: Percentage of urban population in Romania exposed to concentrations above EU standards139 Pollutant 2015 2016 2017 2018 2019 BaP Annual mean N/A N/A N/A 50.0 50.0 NO2 Annual mean 0.6 0.0 1.0 1.5 2.5 O3 Percentile 93.15 0.0 0.0 36.3 1.2 0.0 PM2.5 Annual mean 25.0 25.0 33.9 30.7 25.0 Annual mean 43.3 36.9 43.0 40.3 40.8 PM10 Percentile 90.41 54.4 0.0 22.9 3.7 10.2 Romania is divided into 54 zones/agglomerations for the purpose of assessing compliance with AAQD limit/target values and reporting. In 2017, five zones/agglomerations reported exceedance of the annual mean limit value for NO2 (including Bucharest), four for PM10 (including Bucharest), and two for PM2.5. 139 EEA. 2021. Romania – Air pollution country fact sheet. https://www.eea.europa.eu/themes/air/country-fact- sheets/2021-country-fact-sheets/romania 86 Sustainable Cities Implementation Framework – Air Quality In June 2017 the European Commission sent a letter of formal notice 140 to Romania concerning systemic failures to monitor pollution across its territory in compliance with the AAQD. In July 2019, Romania was notified of its obligations pertaining to monitoring under the AAQD once more141. Specifically, issues relating to the number and type of air quality sampling points were identified. In addition, the Commission referred Romania to the European Court of Justice in 2018 for exceeding PM10 levels, and separately in 2021 for failing to produce an NAPCP as required by the NECD142. Romania operates a National Air Quality Monitoring Network which publishes near real-time data online143. A summary of monitoring stations used to report data to the European Environment Agency for selected pollutants is provided in Table 13. Table 13: Monitoring stations used to report data to the European Environment Agency Pollutant Traffic Urban/suburban Industrial Rural Total background PM10 13 32 18 10 73 PM2.5 0 18 1 0 19 NO2 9 14 18 9 50 BaP 0 3 0 0 3 CURRENT STATUS AND GAP ANALYSES POLICY AND LEGISLATION Romania has failed to report a National Air Pollution Control Program (NAPCP) to the European Commission, which makes understanding the current legislative and policy structure for the country problematic. This failure is the subject of an ongoing infringement procedure by the European Commission. In April 2020, Romania was found guilty of persistent breaches of the Limit Values for PM10 by the European Court of Justice (C-638/18). The development of an integrated air quality plan was initiated in 2019 but it is not clear whether this plan has been completed and adopted. Overall coordination of air quality is the responsibility of the National Agency for Environmental Protection (ANPM), and under Law 104/2011, zones and agglomerations are also required to develop air quality plans where Limit Values are exceeded144. For example, a copy of Bucharest’s Integrated Air Quality Plan can be viewed on the city council’s website145, with annual implementation reports also available. The integration of national local level actions, and the level of implementation of planned actions, cannot be verified. 140 EC. 2017. June infringements package: key decisions. https://ec.europa.eu/commission/presscorner/detail/EN/MEMO_17_1577 141 EC. 2019. July infringements package: key decisions. https://ec.europa.eu/commission/presscorner/detail/EN/INF_19_4251 142 EC. 2021. Air quality: Commission decides to refer Romania to the Court of Justice of the European Union for failure to comply with EU clean air and industrial emissions legislation. https://ec.europa.eu/commission/presscorner/detail/EN/IP_21_6264 143 ReÈ›eaua NaÈ›ională de Monitorizare a Calității Aerului. n.d. https://www.calitateaer.ro/public/home-page/?__locale=en 144 See: https://www.calitateaer.ro/public/management-page/management-page/?__locale=en 145 See: https://doc.pmb.ro/institutii/primaria/directii/directia_mediu/planuri_de_calitate_aer/docs/plan_integrat_calitate_aer_b uc/plan_integrat_calitate_aer_buc_2018_2022.pdf 87 The European Commission’s 2019 Environmental Implementation Review (EIR) concluded that “Romania needs to make additional efforts to meet its emission reduction commitmentsâ€? and that “Air quality in Romania continues to give cause for severe concernâ€?. The review also noted that: “For 2017, exceedances related to the annual limit value for nitrogen dioxide (NO2) were registered in 5 (out of 54) air quality zones (including Bucharest, Cluj-Napoca and Iasi). Exceedances have also been registered related to particulate matter (PM10) in 4 (out of 54) air quality zones (including Iasi, Bucharest and Brasov), and related to fine particulate matter (PM2.5) in 2 (out of 54) air quality zones (Iasi and Brasov). However, due to reporting and monitoring deficiencies the compliance situation cannot be established with certainty. Based on the information received in the ongoing infringement case on monitoring and reporting, Romania promises to correct the reporting as soon as possible and to have the monitoring system up to standard for the start of 2019.â€? Priorities identified include: ï‚· Take action, in the context of the forthcoming national air pollution control programme (NAPCP), to reduce the main emission sources, including through the priority actions below: ï‚· Accelerate the reduction of nitrogen oxide (NOx) emissions and nitrogen dioxide (NO2) concentrations. This will require, for example, further reducing transport emissions, particularly in urban areas (and may require proportionate and targeted urban vehicle access restrictions), and/or using tax incentives; ï‚· Accelerate reductions in particulate matter (PM2.5 and PM10) emissions and concentrations. This will require, for example, further reducing emissions from energy production and heat generation using solid fuels, and promoting efficient and clean district heating; ï‚· Upgrade and improve the air quality monitoring network, and ensure timely reporting of air quality data; ï‚· Reduce the use of coal for domestic heating in order to limit air pollutants emissions, for instance building on the “Coal regions in transitionâ€? initiative. INSTITUTIONS AND CAPACITIES The European Commission’s 2019 EIR notes that Romania relies heavily on EU funds and loans for the implementation of environmental improvement. However, a lack of administrative capacity to deliver such programmes at a national and local level, hinders the effective deployment of such funds. Local authorities clearly have a level of autonomy to develop and implement local air quality improvement actions. However, there is a lack of clarity as to the extent of this autonomy, the sectors influenced, and the integration with national programs. Publication of the NAPCP would be a clear step towards providing such clarity, as would the improvement of online resources to show what action is being taken and not simply the legal obligations currently in place. Serious and structural shortcomings, principally relating to the number and type of sampling locations, have been identified in the air-quality data measured by the Romanian monitoring 88 Sustainable Cities Implementation Framework – Air Quality network, meaning that the situation could potentially be worse than reported to the EU and researchers.146 FINANCING In terms of overall environmental policy, waste management is of highest priority, nationally: in 2016, just under half of environmental expenditure was related to waste management, with a further 20% focused on wastewater management. Pollution abatement, including air pollution, made up just over a quarter of environmental expenditure. Despite this, the European Commission’s 2019 EIR concluded that “ensuring financial resources to reduce the implementation gap should be considered as a priority for the countryâ€?. Priorities identified were: ï‚· Mobilize investment, including through EU funds, to: prevent waste, encourage separate collection and recycling; reduce air pollution; promote sustainable water management, and protect biodiversity and develop green infrastructure; ï‚· Ensure projects are better prepared, better operated, and better prioritised so that EU funds can be used more effectively and better absorbed; and ï‚· Ensure that the rural development programme and greening measures boost biodiversity and contribute to achieving a favourable conservation status of habitats and species. In July 2020, Romania announced a significant extension to the national air quality monitoring network, adding 60 stations, 27 of which would be installed in the Bucharest area. Included in the investment package (just over EUR 3 million) was the development of a mobile app which would draw near real time air quality data from the national network. RECOMMENDATIONS Based on the information above, it is clear that the development, adoption and publication of a clear and comprehensive strategy to address air quality is required at the national level. This needs to incorporate the National Air Pollution Control Program, which will address national emissions, a plan to address urban air quality, and improvements to the quality of the supporting evidence base. Specifically: ï‚· The NAPCP needs to set out measures specifically to address NOx and PM emissions from transport, energy generation and domestic heating and ammonia emissions from agriculture, alongside their implementation structure and financing arrangements. ï‚· The NAPCP also need to set out the structure for coordinating national and local level actions to ensure air pollution hotspots are addressed, linking with city and county authorities and enhancing national capacity for mobilizing finance and implementing actions. 146 European Commission. 2019. „The Environmental Implementation Review 2019 – Country Report Romaniaâ€? - https://ec.europa.eu/environment/eir/pdf/report_ro_en.pdf 89 ï‚· Improvements are needed in the quality control of Romania’s air quality monitoring network as a number of issues have been identified.147 Without a stable and reliable evidence base, it will be difficult to target actions to the areas of greatest need and risks investment being not cost-effective. ï‚· Addressing the high levels of PM2.5 and PAH measured in urban areas in Romania should be a public health priority, with domestic heating as the principal source. Significant measures are required to transition domestic heating away from solid fuels to either gaseous fuels or electricity in the very short term. Replacing coal heating and energy generation will also have significant climate change benefits. ï‚· Measures are also needed to accelerate the uptake of cleaner vehicles, especially in larger urban areas, in particular in the public transport fleet. 147 European Commission. 2019. „The Environmental Implementation Review 2019 – Country Report Romaniaâ€? - https://ec.europa.eu/environment/eir/pdf/report_ro_en.pdf 90 Sustainable Cities Implementation Framework – Air Quality APPENDIX Air quality standards set out in the AAQD are displayed in Table 14. Table 14: Air Quality Standards for the Protection of Human Health (Ambient Air Quality Directive) Pollutant Objective, Legal Nature, & Averaging Period Comments Directives PM2.5 Annual Mean Limit value: 25 µg/m3 PM2.5 Annual Mean Indicative limit value: 20 µg/m3 PM10 Daily Mean Limit value: 50 µg/m3 Not to be exceeded on more than 35 days per year PM10 Annual Mean Limit value: 40 µg/m3 O3 Maximum daily 8-hour Target value: 120 µg/m3 Not to be exceeded on mean more than 25 days per year, averaged over 3 years O3 Maximum daily 8-hour Long-term objective: 120 mean µg/m3 NO2 1-hour Mean Limit value: 200 µg/m3 Not to be exceeded on more than 18 days per year 3 NO2 Annual Mean Limit value: 40 µg/m SO2 1-hour Mean Limit value: 350 µg/m3 Not to be exceeded on more than 24 days per year SO2 Daily Mean Limit value: 125 µg/m3 Not to be exceeded on more than 3 days per year CO Maximum daily 8-hour Limit value 10 mg/m3 mean Benzene Annual Mean Limit value: 5 µg/m3 Lead Annual Mean Limit value: 0.5 µg/m3 Measured as content in PM10 Arsenic Annual Mean Target value: 6 mg/m3 Measured as content in PM10 Cadmium Annual Mean Target value: 5 mg/m3 Measured as content in PM10 3 Nickel Annual Mean Target value: 20 mg/m Measured as content in PM10 3 PAH (as Annual Mean Target value: 1 ng/m Measured as content in BaP) PM10 91 World Health Organization guidelines for PM2.5, PM10, ozone, NO2, SO2 and CO, originally published in 2005 and subsequently updated in 2021, are displayed in Table 15. Table 15: Revised WHO Global Air Quality Guidelines (2021) Pollutant Averaging Interim target (µg/m3) 2021 2005 time 1 2 3 4 Guideline Guideline (µg/m3) (µg/m3) PM2.5 Annual 35 25 15 10 5 10 24-houra 75 50 37.5 25 15 25 PM10 Annual 70 50 30 20 15 20 24-houra 150 100 75 50 45 50 O3 Peak seasonb 100 70 - - 60 - 8-houra 160 120 - - 100 100 NO2 Annual 40 30 20 - 10 40 24-houra 120 50 - - 25 - SO2 24-houra 125 50 - - 40 20 CO 24-houra 7,000 - - - 4,000 - a 99th percentile (i.e. 3–4 exceedance days per year) bAverage of daily maximum 8-hour mean O3 concentration in the six consecutive months with the highest six-month running-average O3 concentration 92