CLM & EJNI Joint Submission to Ireland’s National Air Pollution Control Programme Consultation (NAPCP)

In our joint submission on Ireland’s National Air Pollution Control Programme, CLM & the EJNI call for the National Air Pollution Control Programme Consultation (NAPCP) to be redrafted to address current and projected exceedances in emission compliance limits, just transition concerns, and the transboundary impacts of air pollution with Northern Ireland.

The National Air Pollution Control Programme (NAPCP) and the National Emission Ceilings (NEC) Directive 

EU member states are required to produce a National Air Pollution Control Programme (“NAPCP”), for submission to the European Commission, as part of their obligations under the National Emission Ceilings (“NEC”) Directive. This directive sets mandatory emission reduction targets for certain pollutants, including sulfur dioxide (SO2), nitrogen oxides (NOx), non-methane volatile organic compounds (NMVOC), ammonia (NH3), and particulate matter (PM2.5). NAPCPs have to follow a common format specified in the Commission Implementing Decision (EU) 2018/1522. The first NAPCPs were due by 1 April 2019. Member States submit air pollutants emissions projections every two years, most recently in March 2021. According to Ireland’s draft NAPCP, the NAPCP is to be submitted to the European Commission every fourth year. 

The NEC Directive aims to progress the EU towards the Union’s objective of aligning air quality with the World Health Organisation air quality guidelines, biodiversity and ecosystem objectives as set out within the 7th Environment Action Programme, and coherence between the Union’s air quality policy and climate and energy policies. The NAPCP is intended to serve as a strategic roadmap in achieving the zero pollution ambition announced in the European Green Deal, which aims to protect citizens and ecosystems by better reporting, monitoring, reducing and remedying air pollution. The NAPCP is furthermore essential to the European Green Deal 2030 targets to reduce premature deaths caused by air pollution by 55% and the EU ecosystems where air pollution threatens biodiversity by 25%.9 To achieve these targets, it is critical that EU Member States meet their emission reduction targets for 2020-2029 and from 2030 onwards.10