Proposed air quality limit values possibly not attainable

In the past months, the European Commission, Parliament and Council have all made proposals for tackling air pollution. It appears that it is not feasible to meet the proposed limit values for PM everywhere in Europe in time. The proposed limit values are not consistent with the European ambitions to reduce emissions. Even assuming full implementation of maximum technical feasible reductions and additional traffic measures in urban areas, timely attainment of limit values everywhere in Europe will not be certain. Even the proposed possibilities for derogation offer no solution. Exceedances of the proposed limit values can still occur in the Po-valley, the Benelux-countries, the Ruhr area, in areas in southern and eastern Europe and in several large cities in other countries.

Multiple limit values could hamper enforcement

The daily and annual limit values for PM₁₀ and PM_2.5 partly overlap. In the proposals of European Commission, Parliament and Council the limit values for PM₁₀ remain the most binding restriction in polluted urban areas. This is surprising as WHO has pointed at PM_2.5 as being more relevant for health damage. Only if a correction for natural sources of PM was allowed, would the limit value for PM_2.5 as proposed by Parliament become the most stringent one. The multiple and partly overlapping air quality standards could hamper policy enforcement and there may be a risk that the intended improvement of environmental conditions will not occur. A similar implementation of measurement strategies and methods among member states is already difficult. 

Benefits likely higher than costs

Particulate Matter is associated with premature death, morbidity and hospital admissions. Indications exist that the health benefits exceed the costs of the emission reduction plans of Commission and Parliament. However uncertainties in these estimates remain high.