Eurelectric response to the Public Consultation on the revision of the Ambient Air Quality Directives

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KEY MESSAGES

Eurelectric welcomes the European Commission’s plan to review the Ambient Air Quality Directives. The power sector has, over the last decades, undertaken drastic efforts to reduce both its CO₂ and its non-CO₂ emissions and significantly limit its air pollution. Between 1990 and 2019, emissions of SO₂ and NOx by the electricity industry fell by 95% and 72% respectively, while direct emissions of PM2.5 were reduced by 79%1.

Furthermore, over the next decade, recently agreed source specific European legislation for the energy sector - namely the ongoing implementation of the Best Available Techniques Reference Document for Large Combustion Plants (BREF LCP) and the Medium Combustion Plant (MCP) Directive – and the ongoing phase out of thermal capacity (substituted by a sustained expansion of renewable electricity) will lead to further significant emission reductions.

Our sector intends to continue to pursue and even accelerate this contribution to improving air quality across Europe: the power sector is committed to accelerate the clean energy transition and to achieve carbon-neutral electricity mix in the EU well before mid-century, while ensuring that security of supply is maintained and recognising the increasing challenges for thermal generation. Therefore, additional emission reductions are expected in the decade and beyond, driven by the implementation of the climate and energy policy, the industrial emissions/air quality framework, and the continued desire to invest in carbon-free generation by European utilities.

Supporting the electrification of end use sectors (transport, heating & cooling)

The concept of electrification refers to the idea of broadening the use of electricity to satisfy an increasing proportion of final energy demand of a system. In other words, converting the energy needs of fossil fuel reliant systems with carbon-free electricity. In doing so, many sectors and communities will be able to profit from significant reductions in CO₂ emissions and of air pollutants, and improvements in energy efficiency.

Air pollution in Europe’s urban centres and associated health risks will be significantly reduced if conventional vehicles and heating systems are replaced by electrified systems. Electrification of road transport, specifically in large cities and densely populated areas, means eliminating air pollutant emissions at source where they are most harmful. Similarly, European cities could see a significant improvement in air quality levels as a direct consequence of the electrification of heating.

Transport and residential and commercial heating systems are responsible for a sizeable share of PM 2.5, NOx, and SO₂ emissions in urban settlements. These directly affect the human respiratory system leading to the development and exacerbation underlying medical conditions such as asthma. Electricity-based heating technologies such as heat pumps and smart electronic boilers produce zero emissions at source. Consequently, with increasing levels of electrification of heating in urban centres, an improvement of air quality would be observed.

In order to leverage the benefits of electrification, it is important to adopt an enabling regulatory framework removing barriers to the adoption of electric technologies and network digitalisation supporting sectorial coupling. In particular, Eurelectric wants to emphasise the need for an ambitious clean mobility policy (see Eurelectric position papers on the revised Alternative Fuels Infrastructure Regulationv & CO₂ emission performance standards for cars and vans) and a transition enabling taxation (see Eurelectric position papers on the revised Energy Taxation Directive).

Coherence between policies and better implementation

Eurelectric fully understands the need for and supports an ambitious air quality policy in Europe. We support coherence with the EU's 2030 energy and climate policy and its implementation timeline to achieve better air quality in a cost-effective approach.

In this context, a gradual alignment with the recently revised WHO Air Quality Guidelines by 2040 shall be supported by measures facilitating the uptake of electric solutions in different sectors, and provide power companies and stakeholders with an adequate regulatory certainty. Furthermore, taking into account that many Member States are struggling and sometimes failing to respect the requirements of the current Ambient Air Quality Directives, we would like to highlight the need for a consistent and ambitious approach to air quality between the different governance levels in Member States.


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