Review of the National Air Pollution Control Programme France...The following report presents the...

Review of the National Air Pollution Control Programme – France

___________________________________________________ Final Report for European Commission – DG Environment Specific contract 070201/2018/791186/SER/ENV.C.3

ED 11495 | Issue Number 3 | Date 23/03/2020

Review of the National Air Pollution Control Programme – France | i

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Hetty Menadue

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Date:

23 March 2020

Ricardo Energy & Environment reference:

Ref: ED11495 - Issue Number 3

Review of the National Air Pollution Control Programme – France | ii



Table of contents

1 Introduction ................................................................................................................ 4

Review of the National Air Pollution Control Programmes ................................................ 4

Methodology ...................................................................................................................... 5

NAPCP submission documents ........................................................................................ 6

2 Projected compliance with NECD emission reduction commitments .................... 8

Margin of compliance ........................................................................................................ 8

Projected compliance and consistency with projections submitted under Article 10(2) .... 9

3 Findings of the in-depth NAPCP review ................................................................. 15

NAPCP overview (M) ...................................................................................................... 15

Executive summary (O) ................................................................................................... 15

The national air quality and pollution policy framework (M, O) ....................................... 15

Progress made by current PaMs in reducing emissions and the degree of compliance with

national and EU obligations, compared to 2005 (M, O) .............................................................. 16

Projected situation assuming no change in currently adopted PaMs (M, O) .................. 17

Policy options considered to comply with emission reduction commitments for 2020 and

2030, intermediate emission levels for 2025 and stakeholder consultation (M, O) .................... 18

The policies selected for adoption by sector including timetable for adoption,

implementation and review and responsible competent authority (M, O) .................................. 23

Projected combined impacts of PaMs on emission reductions, air quality and the

environment and associated uncertainties (where applicable) (M, O) ....................................... 25

4 Conclusions and recommendations ....................................................................... 28

Conclusions ..................................................................................................................... 28

Recommendations .......................................................................................................... 29

Appendices

Appendix 1 Completeness assessment

Appendix 2 Assessment of the risk of non-compliance

Review of the National Air Pollution Control Programme – France | iii



Abbreviations BaP Benzo(a)pyrene

BAT Best Available Technique

BC Black Carbon

CH4 Methane

CO2 Carbon dioxide

EEA European Environment Agency

EU European Union

ETS Emission trading system

GHG Greenhouse Gas

kt Kilo tonne

NAPCP National Air Pollution Control Programme

NECD National Emission reduction Commitments Directive (Directive (EU) 2016/2284)

NECP National Energy and Climate Plans

NFR Nomenclature for Reporting

NH3 Ammonia

NMVOC Non-Methane Volatile Organic Compounds

NO2 Nitrogen dioxide

NOx Nitrogen oxides

O3 Ozone

PaMs Policies and Measures

PM10 Particulate matter 10 micrometres or less in diameter

PM2.5 Particulate matter 2.5 micrometres or less in diameter

RAG Red; Amber; Green [rating]

SO2 Sulphur dioxide

WAM With Additional Measures

WHO World Health Organisation

WM With Measures

Review of the National Air Pollution Control Programme – France | 4



1 Introduction

Review of the National Air Pollution Control Programmes

1.1.1 This report

The following report presents the results of the review of the National Air Pollution Control Programme

(NAPCP) submitted to the European Commission by France on 9 October 2019.

EU Member States are required to prepare and report their NAPCP according to the minimum content

and common format (Commission Implementing Decision (EU) 2018/1522)1 stipulated by Article 6 of

the Directive (EU) 2016/2284 on the reduction of national emissions of certain atmospheric pollutants2,

hereafter referred to as the Directive or the NECD3. The NAPCP should demonstrate compliance with

the Member State’s respective emission reduction commitments and set out how compliance will be

achieved.

This review has been undertaken alongside a review of national air pollutant emission projections

developed and reported by Member States under Article 10(2) of the NECD. These reviews have been

commissioned by the European Commission as Service Request 2 under the Framework Contract No

ENV.C.3/FRA/2017/0012 (specific contract 070201/2018/791186/SER/ENV.C.3).

The review of the first NAPCPs and of the air pollution projections with regards to their fulfilment of the

requirements of the NECD will both contribute to the Commission’s reporting on the implementation of

the NECD required under Article 11 of the NECD.

This report feeds into the horizontal review report under the contract which presents conclusions and

recommendations from the review at the EU-level. The horizontal report also contains, for each Member

State, an assessment of its risk of non-compliance with its emission reduction commitments, based on

a cross-analysis of the information provided in the NAPCPs and projection submissions under Article

10(2) of the NECD. This risk assessment is also presented in Appendix 2 to the present report, while

details on the methodology for that complete assessment are found in the horizontal report.

1.1.2 Objectives of the NAPCP review

The purpose of the following report is to determine Member State compliance with the requirements of

the NECD. The scope of the NAPCP review includes:

The use of the NAPCP common format.

NAPCP compliance with the minimum content requirements of the Directive (mandatory content

(M)).

The extent to which the optional content requirements (O) of the Directive are reported and what

added value this brings to the quality of the NAPCP.

Consistency between the NAPCP and the information in the air pollutant emission projections

that were due to be submitted by Member States by 15 March 2019.

The extent to which Member States are reliant on additional PaMs (as included in the ‘With

Additional Measures’ (WAM) scenario) to achieve compliance.

1 Commission Implementing Decision (EU) 2018/1522 of 11 October 2018 laying down a common format for national air pollution control

programmes under Directive (EU) 2016/2284 of the European Parliament and of the Council on the reduction of national emissions of certain

atmospheric pollutants, OJ L 256, 12.10.2018, p. 87.

2 Directive (EU) 2016/2284 of 14 December 2016 on the reduction of national emissions of certain atmospheric pollutants, amending Directive

2003/35/EC and repealing Directive 2001/81/EC, OJ L 344, 17.12.2016, p.1.

3 Directive (EU) 2016/2284 repeals and replaces the previous National Emission Ceilings Directive (2001/81/EC) and is generally referred to as the

new NECD or simply the NECD.




The extent to which the evidence provided on selected PaMs is robust and the level of confidence

it provides that the Member States will achieve their 2020 and 2030 emission reduction

commitments.

The extent to which additional PaMs are put forward in view of wider air quality objectives as

set out in Article 1(2) of the NECD (referring to the objectives of the Ambient Air Quality Directives,

the Union’s long-term objective of achieving levels of air quality in line with the air quality guidelines

of the World Health Organisation (WHO), the Union’s biodiversity and ecosystem objectives

and coherence with climate and energy policy priorities).

The degree of coherence with other plans and programmes in other policy areas,

predominantly the National Energy and Climate Plans (NECP).

Methodology

The key components of the review process are outlined in Figure 1-1. A comprehensive description of

the process, methodology and checks followed are detailed in accompanying review guidelines which

were provided to the NAPCP reviewers responsible for conducting this report.

Figure 1-1 Overview of the NAPCP review methodology

A central review team was used to conduct the initial screening checks. The purpose of the initial

screening was to document Member State submissions in one central data log. For example, the

information recorded includes the date, language and length of the NAPCP submission; accompanying

annexes are similarly reviewed and logged and links to external websites are checked. The initial

checks also record if the Member State uses the NAPCP common format.

The completeness assessment and in-depth review checks are structured according to the section

headings of the NAPCP common format. Together, the review findings inform the extent to which the

NAPCP is compliant with the minimum content requirements, the extent to which evidence is robust

and the level of confidence that the Member State will achieve its commitments.

NAPCP completeness is rated according to a RAG rating (Red, Amber, Green rating as described in

Appendix 1) while the in-depth checks involve a series of questions with pre-defined responses to be

chosen from, designed to systematically determine the robustness and reliability of the evidence

submitted.




NAPCP submission documents

An overview of the Member State’s NAPCP is presented in the table below. This information was

gathered as part of the NAPCP initial screening.

Table 1-1 Overview of the Member State NAPCP submission documents

Initial screening check Response Additional comment

Was the NAPCP submitted by 1 April 2019? No

The NAPCP was submitted after the

reporting deadline, on 9 October

2019.

Was the common format used? Yes

The common format was used but

the section numbering is not

consistent throughout the NAPCP.

What is the length of the NAPCP? 42 pages

What language is the NAPCP reported in? French

What language is the supporting

documentation reported in? French

How many external documents are

referenced or provided in the NAPCP? 7

Is it possible to identify the required

information in the external documents (i.e. is

the page and chapter reference provided)?

No Page and chapter references are not

provided.

Can all external documents be accessed? Yes

Weblinks are provided for the 7

external information sources

referenced. One of the weblinks does

not work but the report is publicly

available online.

Completeness assessment

A completeness assessment was conducted to identify gaps in reporting according to the minimum

content requirements of the common format (Commission Implementing Decision (EU) 2018/1522).

The completeness assessment also reviewed the extent of reporting of optional content by the Member

State. The results show some gaps in Member State reporting, as presented in Appendix 1 to this

review. To summarise, the NAPCP includes the minimum content required for:

The title and date of the NAPCP, and responsible competent authority and contact details (section

2.1.1 of the NAPCP).

National emission reduction commitments and relevant policy priorities for air quality, climate

change and energy (including energy efficiency and renewable energy), transport, agriculture,

domestic heating and industry, and the responsible authorities involved (section 2.2.1 of the

NAPCP).

Progress made by current PaMs in reducing SO2, NOx, NH3, PM2.5 and PM10 emissions (section

2.3.1 of the NAPCP) and improving air quality (section 2.4.2 of the NAPCP).

Projected emissions and emission reductions with existing measures (section 2.5.1 of the NAPCP).




Details concerning the PaMs considered in order to comply with the emission reduction

commitments (reported via the EEA-PaM tool).

Impacts on air quality of the PaMs considered (section 2.6.2 of the NAPCP).

Information on the measures relating to agriculture from Annex III, Part 2 to the NECD (section


Information on the PaMs selected for adoption by sector to comply with the emission reduction

commitments (section 2.7.1 of the NAPCP) and an assessment of how selected PaMs ensure

coherence with policy priorities (section 2.7.2 of the NAPCP).

Projected emissions and emission reductions with additional measures (section 2.8.1 of the

NAPCP). The NAPCP emission reduction projections follow downward linear trajectories (section

2.9.2 of the NAPCP). The use of flexibilities is not reported (section 2.9.3 of the NAPCP).

The completeness assessment found gaps in reporting for the following mandatory reporting

requirements:

Progress made by current PaMs in reducing NMVOC emissions was not reported.

The current transboundary impact of national emission sources was reported to be not estimated

(section 2.4.3 of the NAPCP). France shares borders with Andorra, Belgium, Germany, Italy,

Luxembourg, Monaco, Spain, and Switzerland. Information on the current transboundary impact on

these neighbouring countries should be reported in the NAPCP.

The projected impact on improving air quality was reported to be not estimated (section 2.5.2.1 of

the NAPCP). A qualitative description is required of the projected improvements in air quality and

projected further evolution of degree of compliance (WM scenario) with EU air quality objectives for

NO2, PM10, PM2.5 and O3 values and this is missing.

The Member State has reported the following optional content from the NAPCP common format:

A line chart illustrating the emission reductions per pollutant (section 2.3.1 of the NAPCP) and an

indexed line chart showing the evolution of air quality pollutant concentrations (section 2.4.2 of the

NAPCP).

Associated uncertainties for the NAPCP WM projections to meet the emission reduction

commitments for 2020-2029 and 2030 onwards (section 2.5.1 of the NAPCP).

Information on PaMs reported via the EEA PaM-tool and their expected impact on additional

pollutants to those regulated by the NECD (CO2 and PM10) (reported via the EEA-PaM tool).

Measures to reduce NH3 emissions from livestock manure are among the additional PaMs

considered (relating to the optional measures from Annex III Part 2 to the NECD) (section 2.6.3 of

the NAPCP)




2 Projected compliance with NECD emission

reduction commitments

Margin of compliance

There are several different metrics that can be used to show the “margin of compliance” i.e. the margin

by which compliance with the NECD emission reduction commitments is achieved or missed.

The following two approaches have been used in the overall assessment of NAPCPs and projections

to calculate the margin of compliance:

1. Calculating the difference between an emission reduction commitment and the

projected emission reductions (difference expressed in percentage points) – this

approach is presented in the NAPCP review reports and follows the same approach as required

in the NAPCP format. The emission reduction commitments specified in Annex II of the NECD

are defined as percentage reductions on the 2005 emissions. Projected emissions of pollutants

in 2020 and 2030 are compared to the 2005 emissions to calculate the projected emission

reductions. These projected reductions are then divided by the 2005 emissions to obtain the

projected reductions as a percentage of the 2005 emissions. These percentage reductions are

then compared to the legally binding percentage reduction, with the difference between them

representing the compliance margin expressed as percentage points. As such, negative

percentage points indicate that the emission reduction commitment will not be met.

Figure 2-1 The margin of compliance

Example

A Member State emitted 500 kt of a pollutant in 2005 and had a 20% emission reduction commitment

for 2020. If the 2020 projected emission is 360 kt, the projected emission reduction is 140 kt. This

equates to 28% of 2005 emissions. The projected margin of compliance is 8 percentage points. This

is illustrated in the figure below.

200

250

300

350

400

450

500

550

2005 2010 2015 2020

Emission reduction commitment

(% of 2005 emission)

Compliance margin

Compliance threshold




2. Calculating the difference between projected emissions and the compliance threshold

(expressed as a percentage of the compliance threshold) – this approach is presented in

the projections review reports and follows the same approach as used in the context of

emissions inventories.

Given that each emission reduction commitment specified in Annex II of the NECD is defined as a

percentage reduction on the 2005 emissions, these two values can be combined to express a

“compliance threshold” i.e. the maximum emission that can be emitted by a Member State from 2020

and 2030 onwards, and still be compliant with the emission reduction commitment for a pollutant.

Projected emissions (under the WM and WAM scenarios) can be compared to the compliance

threshold, and the compliance margin expressed as a percentage of the compliance threshold.

Example

A Member State emitted 500 kt of a pollutant in 2005 and had a 20% emission reduction commitment

for 2020. The maximum the Member State can emit in 2020 to achieve its 2020 emission reduction

commitment (the “compliance threshold”) is 400 kt. If the 2020 projected emission is 360 kt, the

commitment will be met by 40 kt and the projected margin of compliance is 10% of the compliance

threshold.

Mathematically these two approaches are different as they use different reference points. However,

they yield the same conclusions concerning compliance or non-compliance with the NECD

reduction commitments. The largest numerical differences between the two approaches occur when

there are significant differences between the 2005 emissions and the projected emissions for 2020 or

2030 (this is in particular the case for SO2).

The percentage point approach is used in the review of the NAPCP to understand the margin of

compliance between the projected emission reductions presented in the NAPCP and the legally binding

percentage emission reduction commitments (see Section 2.2 of this report).

The results of the projections review and of the assessment of the NAPCPs are brought together in the

risk assessment for individual Member States (see Appendix 2 of this report), using the margin of

compliance expressed as a percentage of the compliance threshold based on projections submitted

under Article 10(2). The methodology for assessing the risk of non-compliance is explained in the

accompanying horizontal review report.

Projected compliance and consistency with projections

submitted under Article 10(2)

Under the WM scenario of the NAPCP (based on 2013 projections), the 2020-29 national

emission reduction commitments are projected to be achieved for all pollutants except NH3. The

2030 onwards commitments are projected to be achieved for NOx only.

Under the WAM scenario of the NAPCP (based on 2016 projections), the 2020-29 national

emission reduction commitments are projected to be achieved for all pollutants. The 2030

onwards commitments are projected to be achieved for NOx, NH3 and PM2.5 only.

Projections submitted by France in 2019 under Article 10(2) of the NECD are different to those

included in the NAPCP. Under the WAM scenario, the differences affect the projected margins

of compliance for SO2 and NMVOC.

The projections presented in this section are derived from the information reported by the Member State

in their NAPCP. France included 2013 projections for the WM scenario and 2016 projections for the

WAM scenario, which leads to inconsistency between these two scenarios, as well as the ones reported




under Article 10(2). The historical year of the inventory data underpinning the projections was not

reported in either case, however it would be earlier than the year of the projections used. There is

therefore a high risk of projections used in the NAPCP to be highly outdated. The projections in the

NAPCP are different to the projections data submitted separately by the Member State under Article

10(2) of the Directive on 1 October 2019. The differences affect the conclusions on compliance with

emission reduction commitments for some pollutants as well as projected margins of compliance and

are described below according to the two scenarios.

In addition, the emission reductions presented as kilo tonne in the NAPCP are different to the values

calculated from the percentage reduction values presented (when calculated compared to the 2005

baseline). Under both the WM and WAM scenarios, the differences are marginal for all pollutants (the

differences are between 0.2 and 7 kt) except SO2 and NH3. Under the WAM scenario, the differences

are significant for SO2 (a difference of 300 kt in the year 2020) and NH3 (differences of 23, 27 and 26

kt per commitment year). There is no explanation in the NAPCP to justify this discrepancy and so it is

unclear how and why it has occurred. However, for SO2, it is understood that the discrepancy has

occurred as a result of a reporting error (it is not feasible that the emission reductions presented for the

year 2020 are greater than the 2005 baseline year). To ensure consistency with the other Member State

NAPCP reviews conducted, the projected values presented as kilo tonnes in the NAPCP have been

used for this analysis together with the percentage reduction for all pollutants except for the SO2

projections under a WAM scenario for the year 2020 (where the emission reduction presented in Figure

2-3 is the calculated value using the percentage emission reduction).

In Figure 2-2 and Figure 2-3, the emission reductions needed for 2025 are interpolated according to the

2020-29 and 2030 onwards commitments set out in the NECD. Additional information is included to

demonstrate the extent to which the projections meet the Member State commitments (shown, for each

of the pollutants, as the difference expressed in percentage points between the projected emission

reduction described in the NAPCP and the legal commitment). The percentage points do not represent

the extent to which total emissions projected (kt) compare to the emission reduction commitment (in

terms of kt of emissions).

Under the WM scenario, progress towards the 2020-29 emission reduction commitments is as

follows:

SO2 – The projections of SO2 emissions under the WM scenario show that France can comply with

the 2020-29 reduction commitments specified in the NECD with existing measures. In 2020,

compliance with the emissions reduction commitments is projected to be achieved with a margin of

9 percentage points.

NOx – The projections of NOx emissions under the WM scenario show that France can comply with

the 2020-29 reduction commitments specified in the NECD with existing measures. In 2020,



NMVOC – The projections of NMVOC emissions under the WM scenario show that France can

comply with the 2020-29 reduction commitments specified in the NECD with existing measures. In

2020, compliance with the emissions reduction commitments is projected to be achieved with a

margin of 5 percentage points.

NH3 – The projections of NH3 emissions under the WM scenario show that France cannot comply

with the 2020-29 reduction commitments specified in the NECD with existing measures. In 2020,

compliance with the emissions reduction commitments is projected to be missed with a margin of


PM2.5 – The projections of PM2.5 emissions under the WM scenario show that France can comply

with the 2020-29 reduction commitments specified in the NECD with existing measures. In 2020,






Under the WM scenario, progress towards the 2030 onwards commitments is as follows:

SO2 – The projections of SO2 emissions under the WM scenario show that France cannot comply

with the 2030 onwards reduction commitments specified in the NECD with existing measures. In

2030, compliance with the emissions reduction commitments is projected to be missed with a


NOx – The projections of NOx emissions under the WM scenario show that France can comply with

the 2030 onwards reduction commitments specified in the NECD with existing measures. In 2030,

compliance with the emissions reduction commitments is projected to be achieved exactly.

NMVOC – The projections of NMVOC emissions under the WM scenario show that France cannot

comply with the 2030 onwards reduction commitments specified in the NECD with existing

measures. In 2030, compliance with the emissions reduction commitments is projected to be

missed with a margin of 3 percentage points.

NH3 – The projections of NH3 emissions under the WM scenario show that France cannot comply




PM2.5 – The projections of PM2.5 emissions under the WM scenario show that France cannot comply



margin of 1 percentage point.

Projections submitted by France under Article 10(2) of the NECD in 2019 demonstrate non-compliance

with the 2020-2029 emission reduction commitment for NOx and NMVOC whereas the projections in

the NAPCP demonstrate non-compliance with the 2020-2029 emission reduction commitment for NH3

only. Conclusions on the projected compliance with the 2020-2029 emission reduction commitments

for the SO2 and PM2.5 are the same as presented above but the margins are different.

Projections submitted by France under Article 10(2) of the NECD demonstrate non-compliance with the

2030 onwards emission reduction commitment for NOx and NMVOC whereas the projections in the

NAPCP demonstrate non-compliance with the 2030 onwards emission reduction commitment for SO2,

NMVOC, NH3 and PM2.5 (and compliance with the NOx emission reduction commitment).

These differences in conclusions are likely due to the large time difference between the sets of data

used in various scenarios.




Figure 2-2 Projected attainment of emission reduction commitments (WM scenario used in the NAPCP)

Note: The extent to which the projections meet the Member State commitments is shown, for each of the pollutants,

as the difference expressed in percentage points between the projected emission reduction described in the

NAPCP and the legal commitment. A negative number indicates that a commitment is not met.

As the projections under the WM scenario demonstrate a gap in compliance with the Member State

NECD emission reduction commitments for certain pollutants, the NAPCP includes projections under a

‘With Additional Measures’ (WAM) scenario.

Under the WAM scenario, progress towards the 2020-29 emission reduction commitments is as

follows:

SO2 – The projections of SO2 emissions under the WAM scenario show that France can comply

with the 2020-29 reduction commitments specified in the NECD with additional measures. In 2020,



NOx – The projections of NOx emissions under the WAM scenario show that France can comply




NMVOC – The projections of NMVOC emissions under the WAM scenario show that France can

comply with the 2020-29 reduction commitments specified in the NECD with additional measures.

In 2020, compliance with the emissions reduction commitments is projected to be achieved with a


NH3 – The projections of NH3 emissions under the WAM scenario show that France can comply


compliance with the emissions reduction commitments is projected to be achieved exactly.

PM2.5 – The projections of PM2.5 emissions under the WAM scenario show that France can comply







Under the WAM scenario, progress towards the 2030 onwards commitments is as follows:

SO2 – The projections of SO2 emissions under the WAM scenario show that France cannot comply

with the 2030 onwards reduction commitments specified in the NECD with additional measures. In



NOx – The projections of NOx emissions under the WAM scenario show that France can comply




NMVOC – The projections of NMVOC emissions under the WAM scenario show that France cannot

comply with the 2030 onwards reduction commitments specified in the NECD with additional

measures. In 2030, compliance with the emissions reduction commitments is projected to be

missed with a margin of 1 percentage point.

NH3 – The projections of NH3 emissions under the WAM scenario show that France can comply


2030, compliance with the emissions reduction commitments is projected to be achieved exactly.

PM2.5 – The projections of PM2.5 emissions under the WAM scenario show that France can comply




Projections submitted by France under Article 10(2) of the NECD demonstrate compliance with all the

2030 onwards emission reduction commitments whereas the projections in the NAPCP demonstrate

non-compliance for SO2 and NMVOC. Conclusions on the projected compliance with the emission

reduction commitments for the other years and pollutants are the same as presented above but the

margins are different with smaller margins of compliance projected for all other pollutants.




Figure 2-3 Projected attainment of emission reduction commitments reported in the NAPCP (WAM

scenario) used in the NAPCP’

Notes: The extent to which the projections meet the Member State commitments is shown, for each of the

pollutants, as the difference expressed in percentage points between the projected emission reduction described

in the NAPCP and the legal commitment. A negative number indicates that a commitment is not met.

The projected emissions of SO2 in 2020 have been calculated based on the percentage emission reduction

presented in the NAPCP to account for a reporting error (the emission reductions presented for the year 2020 are

otherwise greater than the 2005 baseline year).

The projected emissions of NH3 (kt) do not correspond with the percentage emission reductions presented in the

NAPCP (by a difference of 23, 27 and 26 kt per commitment year). Thus, while the projected emission values are

below the emission reduction commitments, the percentage point value shows that France is projected to miss the

2025 commitment. Both values are included in this review report because it is unclear how and why the discrepancy

has occurred.

Further analysis related to the risk of non-compliance, taking into account the information provided in

both the NAPCP and the projections submissions, is presented in Appendix 2.




3 Findings of the in-depth NAPCP review

NAPCP overview (M)

The NAPCP was submitted on 9 October 2019, after the deadline (1 April 2019).

The NAPCP is compliant with the common format but the section numbering is inconsistently

used.

A working link to access information on the consultation undertaken in preparation of the NAPCP

is provided but dates several years back.

The NAPCP adheres to the common format specified by the Commission Implementing Decision (EU)

2018/1522, pursuant to Article 6 of the NECD. However, the section numbering in the NAPCP is not

consistently aligned with the common format. The NAPCP is made up of one main report (42 pages in

length). The complete submission was made on 9 October 2019. PaMs were also submitted via the

EEA PaM-tool on 9 October 2019.

Of the seven external links provided in the NAPCP, six are in working order. Nonetheless, all external

references are publicly available online and relate to relevant information sources (national policy

documents (emission reductions, energy and agriculture), guidance documents4 and emission

inventories and air quality statistics).

France reports the title and date for its NAPCP and clearly references the competent authority

responsible for it (the Ministry of Environment, Directorate of Energy and Climate). The information

provided in the submitted NAPCP was published as a different document on 10 May 2017.

The NAPCP includes a weblink directing to the consultation process undertaken for the development

of the 2017 document, but no link directly related to the submitted NAPCP. The consultation was not

extended to neighbouring countries and the transboundary impact of its national emissions was not

reported in the NAPCP.

Executive summary (O)

An executive summary is not reported in the NAPCP. According to the information reported, the NAPCP

is summarised separately and a weblink is provided to access the information5. This external

information source has not been reviewed as part of the NAPCP review.

The national air quality and pollution policy framework (M, O)

Climate and energy policy priorities focus on achieving carbon neutrality by 2050 (section 2.2.1

of the NAPCP).

Relevant policy priorities in other sectors are described for agriculture, transport and domestic

heating.

Air quality policy priorities are only reported as EU air quality standards for PM10, PM2.5, NO2, SO2 and

O3. No reference is made to the WHO guideline values. No detail is reported to explain why these

4 The weblink in the NAPCP is not working but the document is available online: CITEPA (2019) Guide des bonnes pratiques agricoles pour

l'amélioration de la qualité de l'air. https://www.ademe.fr/guide-bonnes-pratiques-agricoles-lamelioration-qualite-lair

5 Plan national de réduction des émissions de polluants atmosphériques (PRÉPA), URL: https://www.ecologique-solidaire.gouv.fr/politiques-

publiques-reduire-pollution-lair#e4 [last accessed 26/11/2019].

https://www.ademe.fr/guide-bonnes-pratiques-agricoles-lamelioration-qualite-lair

https://www.ecologique-solidaire.gouv.fr/politiques-publiques-reduire-pollution-lair#e4





pollutants are prioritised but, for NO2, PM10 and O3, in particular, this corresponds to pollutants that

actually present a challenge6.

National climate and energy policy priorities set out in the NAPCP are to achieve carbon neutrality by

2050, to reduce fossil fuel consumption by 40% between 2019 and 2030 (with the aim of closing the

last coal fuelled installation in 2022) and to reduce GHG emissions by 75% in 2050 compared to a 1990

baseline. Multi-annual programming documents are described as facilitating national action to meet

these objectives and include a multi-annual energy programme 2019-2023 and a National Low Carbon

Strategy.

Relevant agriculture policy priorities cover the restricted use of plant protection products and support

for organic agriculture through public procurement contracts. For transport, the policy priorities reported

cover growth of electric vehicle use, carpooling, and cycling. The transport sector is included among

the sectors to achieve carbon neutrality by 2050. To achieve this, France has committed to a ban on

the sales of carbon fossil cars by 2040 and to increase the number of public charging points for electric

vehicles by five-fold by 2022.

Policy priorities included in the NAPCP also cover improved energy efficiency in buildings and

establishing cleaner domestic heating systems.

Policy making, implementation, reporting and monitoring is carried out at national level by the Ministry

of Environment. National ministry departments corresponding to relevant source sectors are also listed

as involved in policymaking and implementation. National research centres and the national

environment agency are also involved with implementation, as well as monitoring and research. The

respective authorities are responsible for coordinating among themselves. Regional and local

authorities are reported as also being involved in policymaking and implementation. Enforcement roles

are not defined in the NAPCP. The NAPCP review finds that the role of the national government

overseeing air pollution matters will likely facilitate coordination between sectors and regions. It also

finds that local involvement in implementation will likely strengthen implementation through more

targeted action.

Progress made by current PaMs in reducing emissions and

the degree of compliance with national and EU obligations,

compared to 2005 (M, O)

3.4.1 Progress made by current PaMs in reducing emissions

Current PaMs as described cover agriculture, domestic heating, industry and transport. Between

2000 and 2017, current PaMs have contributed to SO2, NOx, NH3, PM2.5 and PM10 emission

reductions.

Progress made by current PaMs in reducing emissions is not reported for NMVOC.

Progress achieved by current PaMs is described between 2000 and 2017 for SO2, NOx, NH3, PM2.5 and

PM10. Progress achieved by current PaMs for NMVOC is not reported and the omission is not explained

in the NAPCP7.

Current PaMs are described with respect to the most significant emission reductions achieved between

2000 and 2017. The degree of compliance with national and Union emission reduction legislation in

6 Air pollution country fact sheets 2018: https://www.eea.europa.eu/themes/air/country-fact-sheets/2018-country-fact-sheets [last accessed:

18/07/2019]

7 The NAPCP includes a weblink to an external data source which includes reporting on NNMVOC. The data source has not been reviewed as part

of the NAPCP review. URL: https://www.citepa.org/fr/secten/ [last accessed 26/11/209].

https://www.eea.europa.eu/themes/air/country-fact-sheets/2018-country-fact-sheets

https://www.citepa.org/fr/secten/




relation to the current PaMs is not described. At a national level, emissions for these pollutants

decreased between this timeframe, as illustrated in the NAPCP by an indexed chart (2000 = 100). By

sector, the main drivers for emission reductions achieved are described as:

Agriculture: Improvements to the storage of livestock manure and application of organic and mineral

fertilisers have contributed to NH3 emission reductions.

Domestic heating: Improvements to the performance of wood burning boilers have led to emission

reductions of PM2.5 and PM10.

Industry: Emission reductions of SO2 have been led by industry as a result of greater use of

renewable energy and energy saving measures. Compliance with EU legislation has also led to

SO2 emission reductions including reduced sulphur-content in the fuels used and environmental

permitting. Adoption of dust abatement techniques by industry has also led to emission reductions

of PM2.5 and PM10.

Transport: Emission reductions of NOx have been led by transport as a result of abatement

technologies being applied (including, but not exclusively, retrofitting catalytic converters) which

have managed to offset emissions from the increased number of vehicles on the road. Compliance

with EU legislation for vehicle standards has also led to NOx emission reductions.

3.4.2 Progress made by current PaMs in improving air quality

Concentrations are presented in an indexed chart (2000 = 100) which shows improvements to air quality

in France for NO2, PM10 and SO2 between 2000 and 2017. O3 concentrations are reported to have

remained fairly constant in this period.

Exceedances of EU air quality standards are reported for NO2, PM10 and O3 between 2000 and 2017.

No exceedances have been reported for SO2 since 2009. For NO2, the number of non-compliant air

quality zones reportedly fell between 2000 and 2017 from 24 to 12. For PM10, the number of non-

compliant air quality zones reportedly fell between 2007 and 2017 as a result of air quality plans

adopted. The types of PaMs implemented as a result of the air quality plans is not reported in the

NAPCP. For both pollutants, road transport is reported as the main challenge affecting ambient

concentrations. O3 concentrations have not changed significantly over time and continues to present a

challenge.

3.4.3 Current transboundary impact of national emission sources

The transboundary impact of national emission sources is not reported. In view of the shared border

with Italy, Germany, Belgium, Spain, Monaco, Andorra, Switzerland, and Luxembourg, the NAPCP

review finds that a transboundary impact of national emission sources is likely.

Projected situation assuming no change in currently adopted

PaMs (M, O)

As reported in Section 2.2 of this report, the 2020-29 national emission reduction commitments are

projected to be achieved for all pollutants except NH3 under a WM scenario. The 2030 onwards

commitments are projected to be missed for all pollutants under a WM scenario except NOx, for which

it is projected to be achieved exactly, with no margin (section 2.5.1 of the NAPCP).

The information is based on projections developed in 2013. The historical inventory data used to

underpin the projections therefore do not accurately reflect the current PaMs adopted in France at the

time of the NAPCP submission in 2019. This adds to the uncertainty of the projections reported under

the WM scenario.

France has not reported the projected impact on improving air quality under a WM scenario (section





Policy options considered to comply with emission reduction

commitments for 2020 and 2030, intermediate emission

levels for 2025 and stakeholder consultation (M, O)

France has reported 50 PaMs via the EEA PaM-tool, targeting agriculture, transport, energy

consumption, industry and cross-cutting.

PaMs reported are not additional because they were adopted in past years.

The estimated emission reduction impact has been quantified for 11 PaMs only.

3.6.1 Summary of the information reported

The assessment presented in this section is based on the information reported via the EEA-PaM tool.

Where relevant, it is complemented with the information from the main body of the NAPCP.

France has reported 50 individual PaMs via the EEA-PaM tool covering four sectors (agriculture, energy

supply, industrial processes, and transport) and cross-cutting measures. A summary of the PaMs

reported via the EEA-PaM tool is provided below in separate tables for each of the sectors.

The PaMs are often not described in much detail. There are examples of broad PaM titles and

incoherent implementation periods, which cannot be clarified by the limited PaM descriptions reported.

For example, in the case of one PaM, emission reductions are quantified for the years 2020 and 2025

but implementation is not planned to start until 2028.

Estimated emission reductions are reported at individual PaM level for 11 of the 50 PaMs reported. The

lack of estimated emission reductions is not explained in the majority of cases. The limited information

means that the PaMs are generally assessed in NAPCP review as having low credibility.

Furthermore, the NAPCP review finds that the PaMs reported are not additional because they were

adopted by national law (2017)8,.

For 43 of the 50 PaMs presented in the NAPCP, the information reported via the EEA PaM-tool can be

further used to confirm that the PaMs are indeed existing measures (these 43 PaMs have been reported

via the EEA-PaM tool as included in the WM scenario). Only seven PaMs have been reported as being

used in the WAM scenario9. However, for these seven PaMs the year of adoption is reported as 2017,

thus it is unclear why they have been reported as additional and used in the WAM scenario.

Energy consumption (domestic heating) (7 individual PaMs)

Reduce the sulphur content in domestic heating oil

Support local authorities in setting up alternative pathways to burning green waste

Ban the sale of garden incinerators

Encourage thermal renovations to domestic housing

Raise public awareness on wood burning appliances and of available aid schemes

8 Arrêté du 10 mai 2017 établissant le plan national de réduction des émissions de polluants atmosphériques.

https://www.legifrance.gouv.fr/jo_pdf.do?numJO=0&dateJO=20170511&numTexte=37&pageDebut=&pageFin=

9 For each PaM reported via the EEA PaM-tool, Member States are required to specify which projections scenario the PaM is included in. The

majority of PaMs are expected to be categorised as ‘with additional measures’, however Member States have the option to report ‘with measures’

and ‘not included’.

https://www.legifrance.gouv.fr/jo_pdf.do?numJO=0&dateJO=20170511&numTexte=37&pageDebut=&pageFin=




Energy consumption (domestic heating) (7 individual PaMs)

Renew heating appliances with more efficient models

Conduct testing for the performance of heating appliances on the market

* The 2017 national legislation includes three further PaMs not reported via the EEA PaM-tool targeted

to the evaluation and reduction of phytopharmaceuticals. These PaMs do not concern emission

reductions.

Industry (6 individual PaMs)

Strengthen regulatory requirements to reduce emissions from the industrial sector (linked to

implementation of EU legislation)

Reduce emissions of volatile organic compounds in the most heavily emitting sectors (conduct a

study to review progress and strengthen implementation of EU regulation accordingly)

Reinforce the general tax on polluting activities on emissions of air pollutants (conduct an inspection

to assess the environmental impact of the system in place)

Test an “air-industry” fund with local authorities

Increase control of industrial installations in the polluted areas as defined by air quality plans

Strengthen the use of emergency measures to limit pollution from industry during peak pollution

periods

Improve the monitoring of classified installations in the most polluted areas

Agriculture (7 individual PaMs) *

Supporting investments to reduce NH3 volatilisation among livestock and during the spreading of

fertilisers

Reduce the volatilisation of NH3 from mineral fertilisers, in particular by reducing their emission

potential, by encouraging their substitution by less emissive fertiliser forms and by adapting the

practices and means through which they are applied (including the verification of the prohibition

against aerial crop spraying)

Limit the burning of agricultural residue as of the 2019-2020 crop year

Mobilising European funding by the regions and drawing up an action plan to control air pollution of

agricultural origin by region

Develop and disseminate good agricultural practices for improving air quality

Pilot projects to disseminate on-farm use of technologies and practices to reduce NH3 and PM2.5

emissions

Reduce the volatisation of NH3 from livestock manure and other organic effluents spread on

agricultural soils




Cross-cutting measures (11 individual PaMs)

Promote good practices in the area of reducing air pollution and the exposure of the population

Transport (18 individual PaMs)

Road transport

Convergence of taxation between petrol and diesel

Align the tax deductibility regimes between petrol and diesel

Promote the deveopment of mobility plans by businesses and administrations

Encourage cycling (deploy an insurance scheme, financial to support to purchase electric bicycles,

mobility plan targeting bicycle use)

Enforce the use of air quality certificates for restricted vehicle zones

Establish restricted vehicle zones

Renew public vehicles fleet to favour low-emission vehicles

Developing clean fuels infrastructure under the national framework for alternative fuels

Encourage the conversion of the most polluting vehicles and the purchase of cleaner vehicles

Supporting the adoption of new, ambitious European standards [light and heavy duty vehicles] (anti-

pollution standards, consideration of real driving conditions and improvement of the approval

procedure)

Monitor real time road vehicle emissions

Reinforce the roadworthiness testing of vehicles

Non road machinery

Reduce emissions from non road machinery (implementation of Regulation (EU) 2016/1628) and

market surveillance of non-road mobile machinery

National aviation

Energy efficiency measures related to transportation at airports

Implementing action plans for civil aviation and aerodromes to reduce emissions of air pollutants

Inland shipping

Develop the connection of ships and boats at berth and infrastructure for maritime and inland

waterway transport

Establish new low emission maritime zones

Limit sulphur in marine fuels and reinforce fuel quality controls (implementation of EU Directive

2014/94/EU)

Develop a roadmap for reducing pollutant emissions from inland shipping




Cross-cutting measures (11 individual PaMs)

Simplify the availability of air quality data and develop knowledge on air quality issues

Improve the degree to which air quality is taken into account in other public policies

Monitor and evaluate actions implemented in areas affected by exceedances of European standards

for pollutant concentrations

Improve [air pollutant] emissions inventory

Make the national day for air quality and the national conferences on air quality regular events

Improve knowledge on the origins of pollution and its impact

Identify and evaluate technologies for reducing and controlling emissions of air pollutants

Mobilise intervention appropriations [funding] for air quality (aid to households and businesses, calls

for projects and studies)

Improve air quality projections

Support community engagement in the implementation of Atmospheric Protection Plans (PPAs)

Anticipating the inclusion of non-regulated pollutants

The analysis in this section reviews the PaMs reported as additional by France, focusing only on PaMs

implemented in 2019 or later. Of the 50 total PaMs reported, only 10 are planned for implementation in

2019 or later. Of these, one refers to the implementation of EU Regulation on non-road mobile

machinery (2016/1628) and therefore has also been excluded from the subsequent analysis. Thus, the

focus in this section of the report is on the following nine PaMs:

Reduce the sulphur content in domestic heating oil (regulatory instrument; planned

implementation in 2028)

Ban the sale of garden incinerators (regulatory instrument; planned implementation in 2020)

Supporting investments to reduce NH3 volatilisation among livestock and during the spreading

of fertilisers (planned implementation to start in 2019)

Mobilising European funding by the regions and drawing up an action plan to control air

pollution of agricultural origin by region (implementation planned to start in 2020)

Develop and disseminate good agricultural practices for improving air quality (planned

implementation to start in 2019)

Reduce emissions of volatile organic compounds in the most heavily emitting sectors (conduct

a study to review progress and strengthen implementation of EU regulation accordingly)

(planned implementation to start in 2019)

Encourage the conversion of the most polluting vehicles and the purchase of cleaner vehicles

(planned implementation in 2021 until 2030)

Develop the connection of ships and boats at berth and infrastructure for maritime and inland

waterway transport (planned implementation to start in 2019)

Set up new low emission maritime zones (planned implementation to start in 2021)




3.6.2 Pollutants targeted and projected emission reductions

Based on the justification set out in the previous section of this report, only nine of the PaMs reported

via the EEA PaM-tool were planned for implementation in 2019 or later at the time of the NAPCP

submissions. Estimated emission reductions were reported for only one of these – to reduce sulphur

content in domestic heating oil (where the planned implementation is due to start in the year 2028).

Estimated emission reductions of SO2 are reported for the years 2020 (10 kt), 2025 (8 kt) and 2030 (6

kt). It is unclear how the PaM is expected to deliver emission reductions before implementation, thus

the credibility of the PaM is very low.

3.6.3 Coherence between the PaMs considered and policy priorities

The related climate and energy policy priorities described in the NAPCP focus on achieving carbon

neutrality by 2050. The PaMs presented in the NAPCP with planned implementation start after 2019

are coherent with this policy priority in terms of clean energy measures for transport and domestic

heating.

PaMs targeting agriculture are also coherent with relevant policy priorities for the sector.

3.6.4 Responsible authorities and timescales for implementation of PaMs considered

Of the 10 PaMs where implementation is planned to start in 2019 or later, implementation is principally

the responsibility of national government ministries responsible for the sector targeted by the PaM.

Where the PaMs involve regulatory, fiscal and source-based policy instruments, the national

environmental authorities are responsible for policymaking and implementation. This can facilitate

consistency between regions and sectors.

For two of the PaMs targeting transport, regional authorities are involved with implementation. This

reflects the scale at which the PaMs are implemented (involving urban areas affected by air quality

issues arising from local road transport issues).

The planned implementation periods for the majority of the individual PaMs is reported to start in 2017

(and one even in 2015) and run indefinitely for the majority of the PaMs reported via the EEA PaM-tool.

As reported already, only 10 of the 50 PaMs adopted are planned for adoption in 2019 or later. As

reported above, planned implementation to reduce the sulphur content in domestic heating oil is

unrealistic – implementation is planned for 2028 but estimated emission reductions are reported for

2020, 2025 and 2030.

3.6.5 Details of the methodology for evaluation and selection of PaMs

The methodology for evaluation and selection of PaMs is provided in a separate document to the

NAPCP10. The report has not been reviewed as part of the NAPCP review.

3.6.6 Estimation of costs and benefits of the individual PaM or package of PaMs

considered

Cost and benefit data was not reported via the EEA PaM-tool but the cost analysis was conducted

during development of the national law adopting the PaMs (dated 10 May 2017). This analysis is

provided in a separate document to the NAPCP11. The report has not been reviewed as part of the

NAPCP review.

10 Annex 4: Methodology used to support the development of the national air pollution programme [Aide à la décision pour l’élaboration du

PREPA » Annexe D Méthodologie employee]. URL: https://www.ecologique-

solidaire.gouv.fr/sites/default/files/03_AnnexeD%20Méthodologie%20employée%20en%20ligne.pdf

11 Ibid.

https://www.ecologique-solidaire.gouv.fr/sites/default/files/03_AnnexeD%20Méthodologie%20employée%20en%20ligne.pdf

https://www.ecologique-solidaire.gouv.fr/sites/default/files/03_AnnexeD%20Méthodologie%20employée%20en%20ligne.pdf




3.6.7 Impacts on air quality and the environment of individual PaMs or packages of

PaMs considered

Impacts on air quality are projected up to 2030 for PM10, PM2.5, NO2 and O3 (section 2.6.2 of the NAPCP)

but with very little detail. The maps provided show projected reductions in concentrations with marked

improvements in urban areas with large volumes of road transport. Despite projected improvements for

O3, exceedances with EU target values are still projected up to 2030.

The number of non-compliant air quality zones is projected to decrease for all four reported air quality

pollutants. By 2020, non-compliant zones are only projected for NO2 (with respect to the 40 µg/m3

average over a year) and O3 (with respect to the accumulated amount of O3 and 120 µg/m3 average

over a daily 8-hour period). The number of non-compliant zones is projected to decrease further

between 2020 and 2030 with 3 non-compliant zones projected for NO2 (from 10 in 2020) and 14 for O3

as an accumulated value (from 32 in 2020).

The policies selected for adoption by sector including

timetable for adoption, implementation and review and

responsible competent authority (M, O)

The NAPCP review finds that only 9 of the 50 individual PaMs selected for adoption are in fact

additional PaMs.

PaMs reported as selected for adoption target all relevant pollutants and sectors.

Coherence with air quality policy priorities is assessed in a separate report and the findings are

not reported in the NAPCP12.

3.7.1 Assessment of the credibility of the PaMs selected for adoption per sector

As reported in Section 3.6.1 of this review report, the PaMs reported by France were actually selected

and adopted by national legislation in 2017 (with varying implementation start years). Information

supporting the development of the national legislation is not reported in the NAPCP and has not been

reviewed as part of the NAPCP review as it is a separate document that was not submitted by France.

Estimated emission reductions were reported for 11 of the PaMs reported via the EEA-PaM tool. This

information is not presented here because all reported emission reductions were found to relate to

existing PaMs.

Of the nine PaMs used in the WAM scenario projections, estimated emission reductions were not

reported for the financial incentive to replace older polluting vehicles with clean energy ones. According

to the justification provided by France, the methodology to estimate the associated impact is not

reported because it was not developed at the time of the NAPCP submission. For the PaMs used in the

WAM scenario, implementation is reported to start from 2015 up to 2028. Implementation start dates in

the past are clearly inconsistent with the definition of additional measures thus the review finds that

these PaMs have been misreported and should have been included in the WM scenario instead. In

most cases, there was around 10 years for the PaMs to deliver the reported emission reductions, which

is considered realistic (albeit incorrectly reported as additional).

12 Plan national de réduction des émissions de polluants atmosphériques (PRÉPA), URL: https://www.ecologique-solidaire.gouv.fr/politiques-

publiques-reduire-pollution-lair#e4 [last accessed 26/11/2019].






Agriculture

The required agricultural measures listed in Annex III, Part 2 to the NECD are part of existing measures

already adopted and being implemented by France according to national legislation adopted in 2017.

The PaMs are reported as not concerning small farms.

In the case of the optional measures listed, France has not established a national nitrogen budget or a

low protein feeding strategy to reduce NH3 emissions from manure. All other optional measures listed

in Annex III, Part 2 have been adopted as part of the 2017 national legislation.

Estimated emission reductions are not reported for any of the PaMs adopted and none of the PaMs are

used in the WAM scenario according to the information reported via the EEA PaM-tool. Thus, it is

unclear how France can achieve the projected emission reductions under the WAM scenario.

Implementation was planned to start in 2017 and while there has been the publication of a good practice

guide to improve air quality from agriculture13, no information is reported in the NAPCP regarding a

review process in place to monitor implementation.

Energy consumption

Estimated emission reductions are reported for two of the PaMs adopted, which are also used in the

WAM scenario according to the information reported via the EEA PaM-tool, as follows:

Reduce the sulphur content in heating oil (regulatory instrument; planned implementation in

2028)

Conduct testing for the performance of heating appliances on the market

The estimated emission reductions reported for the PaM to reduce the sulphur content in domestic fuel

is not credible because the planned implementation period (2028) is later than the projected emission

reductions (which are reported for 2020, 2025 and 2030).

Implementation of the measure consisting in testing the performance of heating appliances on the

market was planned to start in 2017. The description of the PaM does not provide sufficient detail to

justify the estimated emission reductions reported and so the credibility of the PaM is limited.

Transport

Implementation has started for the three PaMs targeting transport, as follows:

Converging taxation between gasoline and diesel (2018)

Real time emission controls (2015)

Establish restricted vehicle zones (2017)

The estimated emission reductions are feasible in the timescales reported (estimated to increase

incrementally from 2020 up to 2030).

Implementation of a financial incentive to replace older polluting vehicles with clean energy ones is

planned for 2021. The scale of the PaM is not described, and estimated emission reductions were not

reported and so the expected impact of the PaM cannot be determined. As such, the credibility of the

PaM is limited.

Cross-cutting

Of the cross-cutting PaMs adopted by national legislation in 2017, only one is used in the WAM scenario

according to the information reported via the EEA PaM-tool. The measure involves calls for research to

identify and evaluate technologies for reducing and controlling emissions of air pollutants and is

expected to deliver PM2.5 emission reductions from 2020 up to 2030. Examples of projects reported via

13 CITEPA (2019) Guide des bonnes pratiques agricoles pour l'amélioration de la qualité de l'air. https://www.ademe.fr/guide-bonnes-pratiques-

agricoles-lamelioration-qualite-lair






the EEA PaM-tool are: evaluation study on the efficiency of technologies to reduce PM emissions linked

with braking and tyre abrasion; study on available alternatives to burning practices on agriculture land

(with respect to permanent crops such as vineyards); research into the impact of vegetation in cities;

and the development of tools to monitor real time emissions from road vehicles. It is unclear how the

reported emission reductions from that PaM were estimated given the PaM concerns only

commissioning of research projects.

Implementation was planned to start in 2017. The description of the PaM does not provide sufficient

detail to justify the estimated emission reductions reported and so the credibility of the PaM is limited.

3.7.2 Feedback from the consultation undertaken

There is no information provided on the consultation comments received, nor in general nor for the

individual or packages of PaMs selected for adoption,. Information in the NAPCP signposts to where

consultation responses were gathered at the time of the previously adopted programme (see Section

3.1 of the review)

3.7.3 Sources of funding

Information on the sources of funding is not reported.

3.7.4 Coherence with plans and programmes set up in other relevant policy areas

According to the information reported in the NAPCP, coherence between the selected PaMs and plans

and programmes for other relevant policy areas was assessed in 2015 to develop the air pollution

control plan adopted by national legislation in 2017. Multi-criteria analysis was conducted at the level

of individual PaMs based on the estimated emission reduction of each PaM, its potential contribution to

air quality improvements and the cost benefit ratio. This information is now very old and has not been

reviewed here as it is not included in the NAPCP and references have not been provided to identify the

external sources.

Projected combined impacts of PaMs on emission

reductions, air quality and the environment and associated

uncertainties (where applicable) (M, O)

Under the WAM scenario of the NAPCP (based on 2016 projections), the 2020-29 national

emission reduction commitments are projected to be achieved for all pollutants. The 2030

onwards commitments are projected to be achieved for NOx, NH3 and PM2.5 only.

The NAPCP review finds that a linear emission trajectory is not followed for NH3.

3.8.1 Likelihood of achievement of projected emission reductions

According to the projections included in the NAPCP, under the WAM scenario (based on 2016

projections), the 2020-29 national emission reduction commitments are projected to be achieved for all

pollutants. The 2030 onwards commitments are projected to be achieved for NOx, NH3 and PM2.5, and

missed for SO2 and NMVOCs. Conclusions from the NAPCP review on whether the projected emission

reductions per pollutant are likely to be realised in practice are presented in Table 3-1.




Table 3-1 Likelihood of achieving the projected emissions reductions (WAM scenario)

Do the PaMs selected for adoption target

the key emitting sectors?

Are the projected emission reductions for

2020 and 2030 likely to be achieved?

SO2 Partly.

In 2017, combustion in industry was the

main source of SO2 emissions in France,

followed by combustion in other sectors.

The most significant contribution estimated

for the PaMs reported target emissions

from domestic heating.

No.

The planned implementation date of the

PaM expected to deliver the greatest SO2

emission reductions is after the period in

which estimated emission reductions are

reported. It is therefore unclear how the

PaM will deliver the estimated emission

reduction before it is implemented.

Furthermore, the detail of the PaM is not

clearly defined and so there is insufficient

information to determine its credibility.

NOX Yes.

In 2017, emissions from road transport

were the main source of NOx in France.

The most significant contribution estimated

for the PaMs reported target emissions

from road transport.

Partly.

Implementation was underway at the time

of the NAPCP submission (started in

2017). This allows for sufficient time to

achieve the estimated emission reductions

for 2020 onwards. Estimated emission

reductions are expected to increase

incrementally up to 2030. However, the

detail of the PaM is not clearly defined and

so there is insufficient information to

determine its credibility.

NMVOC No

NMVOC emissions in France came

predominantly from solvent and other

product use in 2017. However, the only

estimated emission reductions for NMVOC

come from PaMs targeting road transport.

Partly.

Implementation of relevant PaMs was

underway at the time of the NAPCP

submission (implementation started in

2017). This allows for sufficient time to

achieve the estimated emission reductions

for 2020 onwards. Estimated emission

reductions are expected to increase

incrementally up to 2030. However, the

detail of the PaMs is not clearly defined

and so there is insufficient information to

determine its credibility.

NH3 No.

Agriculture was the main source of NH3

emissions in France in 2017. The only

contribution estimated for the PaMs

reported target emissions from road

transport.

No.

The projected emission reductions under

the WAM scenario do not correspond to

the estimated emission reductions

reported for the PaMs. The detail of the

PaMs is not clearly defined and so there is

insufficient information to determine their

credibility.




Do the PaMs selected for adoption target

the key emitting sectors?

Are the projected emission reductions for

2020 and 2030 likely to be achieved?

PM2.5 Yes.

Combustion in other sectors was the main

source of PM2.5 emissions in France in

2017. The most significant contribution

estimated for the PaMs reported target

emissions from domestic heating (calls for

research to identify and evaluate

technologies for reducing and controlling

emissions of air pollutants).

Partly.

Implementation was underway at the time

of the NAPCP submission (started in 2017).

This allows for sufficient time to achieve the

estimated emission reductions for 2020

onwards. Estimated emission reductions

are expected to increase incrementally up

to 2030. It is unclear how the reported

emission reductions from that PaM were

estimated given the PaM concerns only

commissioning of research projects.

This analysis of the credibility of the PaMs in achieving emission reductions has also been used in the

assessment of the risk of non-compliance, presented in Appendix 2.

3.8.2 Deviation from the linear trajectory for 2025

It is reported that linear emission reduction trajectories are followed for all NECD pollutants.

The NAPCP review finds that a linear emission trajectory is not followed for NH3. However, the extent

to which the linear emission trajectory is not observed is minor (a degree of 1 percentage point) and the

NH3 2020-29 and 2030 commitments are projected to be achieved. Furthermore, it is not possible to

establish which of the emission reduction values reported (as kt or as a percentage of the 2005 baseline

year) is the correct projection data (Section 2.2). The deviation from the linear trajectory is specific to

the projected emission trajectory when using the emission reductions calculated as a percentage of the

2005 baseline year. Therefore, the NAPCP review finds that the description reported by France in the

NAPCP is adequate on this matter.

3.8.3 Use of flexibilities

No information with regard to flexibilities is reported. Therefore, it is assumed that flexibilities are not

applicable.

3.8.4 Projected impacts on air quality and the environment.

The projected impacts on air quality and the environment are not reported for PaMs selected for

adoption.




4 Conclusions and recommendations

Conclusions

France did not meet the reporting deadline, submitting its NAPCP after the 1 April 2019. The common

format established by the Commission Implementing Decision (2018/1522) has been used and so has

the EEA-PaM tool.

The minimum content is provided for many aspects of the NAPCP. However, reporting gaps are evident

which affect the quality of the NAPCP, as follows:

Progress made by current PaMs in reducing NMVOC was not reported.

The current transboundary impact of national emission sources was not reported.

Under the WM scenario, the projected impact on improving air quality is not reported.

Although projections are presented in the NAPCP, the information reported is outdated as it is based

on 2013 and 2016 projections and a report adopted by France in 2017. Furthermore, the differences

identified between the emission reduction values reported as kt compared to the values calculated as

a percentage of the 2005 baseline year bring in to question the quality of the projections data presented

in the NAPCP.

The NAPCP review finds that the PaMs reported are not additional. They already exist and form part of

national legislation adopted in 2017. Therefore, the NAPCP review finds that these PaMs should be

included in the WM scenario rather than being presented as additional PaMs for inclusion in the WAM

scenario. The fact that the PaMs relate to existing PaMs rather than additional ones means that the

projected emission reductions associated with them would have resulted in lower emissions under the

WM scenario, and less reduction under the WAM scenario. However, the overall compliance gap from

the commitments would be the same as projected under the WAM scenario.

According to the NAPCP projections under the WAM scenario, France is not expected to meet its

national emission reduction commitment for SO2 and NMVOC for 2030 onwards. The PaM targeting

emission reductions of SO2 (as reported by France via the EEA PaM-tool), is judged in the review as

having low credibility because the planned implementation is after the period in which estimated

emission reductions are reported. For NMVOC, the only emission reductions from the PaMs reported

will be achieved in the road transport sector and are minor. The NAPCP review concludes that additional

PaMs are needed and could be better targeted to the key emitting sources for these pollutants (i.e.

combustion in industry and solvent use).

According to the NAPCP projections reported under the WAM scenario, compliance with the 2030

commitments for NOx, NH3 and PM2.5 is projected to be achieved by 3, 0 and 5 percentage points,

respectively. The differences between the NAPCP projections and the projections submitted under

Article 10(2) do not affect the conclusions on compliance for these pollutants (Section 2.2 of this report).

The estimated emission reductions are dependent on the implementation of PaMs which were adopted

by national legislation in 2017. The NAPCP review finds that the detail of the PaMs is not clearly defined

and so there is insufficient information to determine the credibility of the PaMs.

These findings are flagged in the risk assessment presented in Appendix 2 to this report; however, no

conclusions have been drawn on the risk of non-compliance as the late submission of the Article 10(2)

projections meant that the quality could not be reviewed as part of the projections review that was

conducted ahead of the French NAPCP review.

A positive counterpart to the fact that France has reported already existing PaMs instead of the required

additional ones is that the NAPCP provides a detailed description of current PaMs together with

implemented EU legislation that provides a good basis for understanding progress achieved to date.




Recommendations

Recommendations are prioritised according to the following categories:

1. Ensuring compliance – non-compliance with the NECD, where the minimum content is not

reported and/or the Member State does not demonstrate how it may achieve its emission reduction

commitments.

2. Areas for improvement – the NAPCP is reported to be compliant with its emission reduction

commitments and provides the minimum content required by the common format but areas for

improvement to strengthen compliance have been identified.

3. Encouragements – where optional reporting and/or the NAPCP could be closer aligned with the

guidance document on preparation of initial NAPCPs to strengthen the quality of the NAPCP.

Ensuring compliance

According to the NAPCP projections under the WAM scenario, SO2 and NMVOC 2030 onwards

commitments are projected to be missed. To ensure compliance, France should consider and adopt

further additional PaMs. The NAPCP review finds that further additional PaMs could target SO2

emissions from combustion in industry and NMVOC emissions from solvent use.

Progress achieved by current PaMs for NMVOC is not reported in the corresponding section of the

NAPCP. France is required to report on progress achieved by current PaMs and the degree of

compliance with national and Union emission reduction legislation for all NECD pollutants.

Where relevant, Member States are required to describe the current transboundary impact of

domestic emission sources. France has reported that this has not been estimated. This response

is insufficient and these impacts need to be reported.

Member States are required to report the policy options considered in order to comply with the

emission reduction commitments for 2020-29, and 2030 onwards. These shall be additional to

existing PaMs, i.e. they shall not include implementation of existing EU legislation and they shall

not include PaMs where national implementation was already underway at the time of the NAPCP

submission. All PaMs reported via the EEA-PaM tool by France were adopted by national legislation

in 2017 with implementation starting in the year 2015 in some cases and therefore are not

additional. To ensure compliance, France is required to present information for additional PaMs, at

least for SO2 and NMVOC.

Areas for improvement

The NAPCP projections under a WM scenario were developed in 2013. Existing PaMs adopted

between 2013 and 2017 are therefore not captured by the inventory data used to underpin the

projections. This adds to the uncertainty of the projections. The NAPCP projections under the WAM

scenario were developed in 2016. None of the NAPCP scenarios is consistent with projections

reported in 2019 under Article 10. Consistency should be sought between all scenarios based on

latest data.

Under the WAM scenario, the respective emission reduction commitments for NOx (for 2030

onwards), NH3 (for 2020-29 and 2030 onwards), and PM2.5 (for 2030 onwards) are projected to be

achieved by 3, 0 and 5 percentage points, respectively. To strengthen the certainty with which

France can meet the respective commitments according to the emission reductions projected in the

NAPCP, France should consider and adopt additional PaMs.

The climate and energy policy priorities reported and the coherence assessment with relevant

priorities do not cover the National Energy and Climate Plan (NECP). It is recommended that France

reports on how coherence with the NECP has been achieved.




Encouragement

Air quality policy priorities and impacts are not described in any detail, nor are the costs of the

measures. France is encouraged to present more information in the NAPCP on this.




Appendix 1 Completeness assessment

A completeness assessment was conducted to identify gaps in reporting according the minimum

content requirements of the common format (Commission Implementing Decision (EU) 2018/1522).

The completeness assessment also reviewed the extent of optional reporting by Member States.

For mandatory reporting requirements, the status has been assessed using the traffic light RAG rating

as presented in the table below.

Table A1 - 1 Traffic light RAG rating for completeness assessment of mandatory reporting

Red No information provided for mandatory reporting requirement

Amber Evidence is incomplete or unclear to meet reporting requirement

Green Evidence is sufficient to meet reporting requirement

N/A Mandatory reporting requirement not relevant for the given Member State or

mandatory only when available and not available in the given Member State (e.g.

where mandatory reporting requirements apply only where a non-linear emission

reduction trajectory is followed)

Table A1 - 2 Assessment of the NAPCP compliance screening with the minimum content requirements

Reference to the NAPCP common

format

RAG

Rating

Explanation

2.1 Title of the programme contact

information and websites

Green The NAPCP is appropriately introduced.

2.3.1 Policy priorities and their

relationship to priorities set in other

relevant policy areas

Green France reported policy priorities for emission

reductions and other relevant policies

already in place, as regards air quality,

climate change and energy, transport and

agriculture.

2.3.2 Responsibilities attributed to

national, regional and local authorities

Green The NAPCP meets all reporting

requirements relating to the responsibilities

attributed to national, regional and local

authorities.

2.4.1 Progress made by current PaMs in

reducing emissions, and the degree of

compliance with national and Union

emission reduction obligations

Red Progress made by current PaMs in reducing

NMVOC was not reported and it is unclear

what are current and new PaMs (since what

is reported as new PaMs are actually part of

the existing ones).


improving air quality, and the degree of

compliance with national and Union air

quality obligations

Green France reported progress achieved by

current PaMs in improving air quality for

select air pollutants and described

compliance.

2.4.3 Where relevant, current

transboundary impact of national emission

sources

Red The current transboundary impact of national

emission sources was not reported.





format

RAG

Rating

Explanation

2.5.1 Projected emissions and emission

reductions (WM scenario)

Amber France reported projections under a WM

scenario based on 2013 projections,

showing emission reductions compared with

a 2005 base year for all NECD pollutants

against the Member State commitments (as

stipulated by the NECD). The year of the

inventory data used to underpin the

projections was not reported but is

necessarily older than 2013.

2.5.2 Projected impact on improving air

quality (WM scenario)

Red The projected impact on improving air quality

is not reported

2.6.1 Details concerning the PaMs

considered in order to comply with the

emission reduction commitments

(reporting at PaM level)

Amber France provides the minimum content for

this reporting requirement using the EEA

PaM-tool. However, the PaMs reported are

not additional according to the NAPCP

review.

2.6.2 Impacts on air quality and the

environment of individual PaMs or

packages of PaMs considered in order to

comply with the emission reduction

commitments (where available)

Amber France reported the minimum content for

this reporting requirement in the NAPCP.

However, the PaMs reported are not

additional according to the NAPCP review.

2.6.4 Additional details concerning the

measures from Annex III Part 2 to

Directive (EU) 2016/2284 targeting the

agricultural sector to comply with the






review.

2.7.1 Individual PaMs or package of PaMs

selected for adoption and the competent

authorities responsible





review.

2.7.2 Assessment of how selected PaMs

ensure coherence with plans and

programmes set up in other relevant

policy areas

Amber France reported the minimum content for

this reporting requirement in the NAPCP.

However, the PaMs reported are not

additional according to the NAPCP review.

2.8.1 Projected attainment of emission

reduction commitments (WAM)

Amber France reported projections under a WAM

scenario based on 2016 projections,

showing emission reductions compared with

a 2005 base year for all NECD pollutants

against the national commitments (as

stipulated by the NECD). The year of the

inventory data used to underpin the





format

RAG

Rating

Explanation

projections was not reported but is

necessarily older than 2016.

2.8.2 Non-linear emission reduction

trajectory

Amber The NAPCP review finds that a linear

emission trajectory is not followed for NH3 (by

a degree of 1 percentage point). However,

the NH3 2020-29 and 2030 commitments are

projected to be achieved. Therefore, the

NAPCP review finds that the lack of

description reported by France in the NAPCP

is not a significant reporting gap.

2.8.3 Flexibilities n/a Flexibilities are not used.

The rating used for the completeness assessment of optional reporting by Member States refers to only

two categories, whereby the Member State either reported the information (Green) or it did not (White).

This rating reflects the fact that the reporting is optional and therefore where the information was not

provided, or where it was incomplete or unclear, the assessment should not consider this a gap in

reporting.

Table A1 - 3 Rating for completeness assessment rating of optional reporting

Green Evidence is sufficient to meet reporting requirement

White No information provided for optional reporting requirement or evidence is

incomplete or unclear to meet optional reporting requirement

Table A1 - 4 Completeness assessment of the NAPCP for the optional content requirements


format

RAG

Rating

Explanation

2.2 Executive summary White Only an external weblink is provided to an

executive summary that relates to an older

document.

2.3.1 Policy priorities and their

relationship to priorities set in other

relevant policy areas: Reference to WHO

guideline values

White France has not reported any information on

this aspect.

2.3.2 Responsibilities attributed to

national, regional and local authorities:

Source sectors under the responsibility of

the authority


this aspect.


reducing emissions, and the degree of

compliance with national and Union

Green A line chart illustrating the emission

reductions per pollutant is provided.





format

RAG

Rating

Explanation

emission reduction obligations: Provision

of graphics


improving air quality, and the degree of

compliance with national and Union air

quality obligations: Provision of graphics

and progress made in a specific air quality

zone

Green An indexed line chart showing the evolution

of air quality pollutant concentrations is

provided.

2.4.3 Methodologies and data used to

show the current transboundary impact of

national emission sources


this aspect.

2.5.1 Associated uncertainties of the

projected emissions and emission

reductions (WM scenario)

Green Associated uncertainties for the WM

projections to meet the emission reduction

commitments for 2020, 2025 and 2030

onwards is reported.

2.5.2 Quantitative data on the projected

impact on improving air quality (WM

scenario)


this aspect.

2.6.1 Details about additional pollutants

concerning the PaMs considered in order

to comply with the emission reduction

commitments: Reporting of affected

pollutant(s) beyond the scope of the

NECD


this aspect.

2.6.3 Estimation of costs and benefits of

the individual PaM or package of PaMs

considered in order to comply with the


White An external weblink is provided to an annex

for the older document.

2.6.4 Additional details concerning the

optional measures from Annex III Part 2 to

Directive (EU) 2016/2284 targeting the

agricultural sector to comply with the


Green Information on optional agricultural

measures is reported in the NAPCP.

2.7.1 Individual PaMs or package of PaMs

selected for adoption and the competent

authorities responsible: Reporting of

relevant comments arising from the

consultation and provision of interim

targets and indicators


this aspect.

2.7.2 Explanation of the choice of

selected measures


this aspect.





format

RAG

Rating

Explanation

2.8.4 Projected improvement in air quality

(WAM)


this aspect.

2.8.5 Projected impacts on the

environment (WAM)


this aspect.




Appendix 2 Assessment of the risk of non-compliance The description of the methodology used for this assessment is presented in the Horizontal Report.

In the following tables, the information used in the decision tree process is presented in black font.

Information not used in the decision tree process is presented in grey font and italics.

Where information is required but not reported, the response to the decision tree question is ‘not

reported’ (NR). Where information is not required and not reported, the response to the decision tree

question is ‘not applicable’ (n/a).

Risk of non-compliance with 2020-2029 emission reduction commitments

Decision tree question Relevant

scenario

2020 – 2029

SO2 NOx NMVOC NH3 PM2.5

Can the Member State

achieve the emission

reduction commitments?

(projections submitted

under Article 10(2))

WM Yes No Yes No Yes

WAM Yes Yes Yes Yes Yes

Are the projections

submitted under Article

10(2) considered to be of

good quality?

WM,

WAM

Are the NAPCP projections

consistent with the latest

projections submitted under

Article 10(2)?

WM No No No No No

WAM No No No No No

Does the NAPCP present

credible additional PaMs

selected for adoption?

WAM No Partially Partially No Partially

Is the margin of compliance

(percent of the compliance

threshold) likely to ensure

compliance with the

emission reduction

commitments? (projections


10(2))

WM Yes

(47)

No (-3) Yes

(13)

No (-3) Yes

(22)

WAM Yes

(53)

Yes (6) Yes

(12)

No (0) Yes

(22)

Risk of non-compliance

Additional comments on

high risk scores

The late submission of projections under Article 10(2) meant that

the quality of projections was not reviewed as part of the

projections review which was carried out in 2019. The risk

assessment thus could not be completed.




Risk of non-compliance with 2030 emission reduction commitments

Decision tree question Relevant

scenario

2030 onwards

SO2 NOx NMVOC NH3 PM2.5

Can the Member State

achieve the emission

reduction commitments?

(projections submitted

under Article 10(2))

WM Yes No Yes No Yes

WAM Yes Yes Yes Yes Yes

Are the projections


10(2) considered to be of

good quality?

WM,

WAM

Are the NAPCP projections

consistent with the latest

projections submitted under

Article 10(2)?

WM No No No No No

WAM No No No No No

Does the NAPCP present

credible additional PaMs

selected for adoption?

WAM No Partially Partially No Partially

Is the margin of compliance

(percent of the compliance

threshold) likely to ensure

compliance with the

emission reduction

commitments? (projections


10(2))

WM No (4) No (-10) Yes (6) No (-7) Yes (2)

WAM Yes

(31)

Yes

(16)

Yes (8) No (3) No (0)

Risk of non-compliance

Additional comments on

high risk scores

The late submission of projections under Article 10(2) meant that

the quality of projections was not reviewed as part of the

projections review which was carried out in 2019. The risk

assessment thus could not be completed.

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