Policy papers

Could new EU targets melt into air?

14 March 2023

How would you rate air quality legislation that will have difficulty improving overall air quality, will not be acted upon in time, and is undermined by other regulations? If we don’t close loopholes now, warns Eurocities Air Quality Expert Thomas Lymes, this could be what the EU’s revised Ambient Air Quality Directive leaves us with.


The new Air Quality Directive contains solid and appropriate ambitions, Lymes explains. However, other EU legislation that have a direct bearing on air quality, such as those related to how much pollution new vehicles can emit, will not do enough to prevent far higher levels.

For example, the new Euro 7 regulation, which tackles this directly, is presenting seriously watered down ambitions that do not support EU goals on air quality. “It’s like your doctor telling you, ‘You have to lose weight, but there’s no need to stop eating junk food,’” Lymes says.

The same worrying trend is visible in relation to a proposed ban on petrol and diesel cars, something that, Lymes says, cities desperately need. The EU put forward a regulation on this which looked set to take effect by 2035.

However, in a sudden sea-change, certain member states are beginning to put obstacles in the way of this vital target. Road traffic is still one of the main sources of air pollution in our cities, so if the EU doesn’t act on this now, Lymes says, the prospects for future targets may be rather grim.

To achieve consistency between air quality rules and sectorial legislation, says Lymes, cities want to see the directive include formal responsibility for achieving the objectives on the part of member states and the European institutions. “When a team sets off to build a house,” Lymes says, “everyone from the architect to the bricklayer needs to be working to the same plans.”

Everyone from the architect to the bricklayer needs to be working to the same plans
— Thomas Lymes

At the moment, the position of the Commission, and the member states, is like that of a team of architects that don’t all seem to have the same building in mind. “If they’re serious about these goals,” Lymes says, “then we need a unified blueprint and a strong foundation.”

It’s important to think of air quality as a multi-level issue, involving local, national and EU government, as pollution knows no boarders – pollution created in one place can end up in another.

National action may also be necessary where local administrations have to deal with high levels of air pollution coming from outside their territory. Besides this, some types of air pollution, such as ozone, result from industrial and agricultural processes that can only be tackled at national level.

The air where?

The previous version of the Ambient Air Quality Directive had a serious issue in that it focussed on ‘hotspots,’ parts of cities where air pollution was extremely high. This meant that you could meet its goals by pushing the pollution in these hotspots to other areas of the city, without reducing the overall exposure.

A lot of people live near highways – don’t they have a right to clean air like the rest of us?
— Thomas Lymes

Now, the directive is focused on the average exposure people have to pollution, but in order to ensure that the average isn’t disrupted by outlying data, guidelines say you shouldn’t place monitoring devices near highways or in other locations where pollution is likely to be unusually high. “This begs the question,” Lymes says, “a lot of people live near highways – don’t they have a right to clean air like the rest of us?”

Real reductions?

The key question that a directive on air quality must ask is whether ambitions on paper will translate to real reductions in air pollution. The omission of a ‘phased approach,’ says Lymes, makes success far less likely. “Cities have tight budgets,” Lymes explains, “and spending rules that make it hard for them to invest in long-term projects. If the target is ten or twenty years away, it’s hard for them to justify spending now.”

Cities have tight budgets
— Thomas Lymes

The likely outcome of this is that sufficient measures may only be put in place when the deadline is close, at which point it will already be too late. Similar patterns can be observed at national level.

That’s why Lymes insists that the revised directive must include a requirement for the responsible authorities to start working towards its objectives by updating their air quality plans as soon as the directive enters into force.

Another major issue that the directive highlights are ‘pollutants of emerging concern’ – that’s polluting particles that we don’t understand very well yet, either in terms of how they behave or their effects on human health.

However, the directive only says that these must be measured, rather that mandating action to deal with them once they’re better understood. “It could be a decade before an updated directive is released,” says Lymes, “meaning that we will be living with types of pollution that we have since learned are harmful and yet have no rules for tackling properly.”

People power

“Why do we need air quality regulations?” Lymes asks rhetorically, answering, “for one reason: to improve the health and quality of life of local people.” Nevertheless, he warns against framing people as passive beneficiaries of policy. “If people are not engaged and empowered,” says Lymes, “then it may seem that these measures are being done ‘to’ them, not with them.”

Cities have found ‘citizen science’ a very effective tool to get local people on board with new air quality policy and allow them to contribute to it in a meaningful way. ‘Citizen science’ means giving locals the tools to perform their own research, for example by measuring air quality from their living room windows.

“Ghent helped residents to measure air pollution with sensors next to their windows about a decade ago. Now, they are even encouraging citizens to measure the impact of their new mobility plans on air quality,” Lymes explains.

This can help people learn more about air quality and how it affects them personally, and can empower them to contribute to, or question local policy. “Early results from Eurocities EU-funded project, Citimeasure, have shown really exciting results on this,” Lymes says.

[Cities] need regular people on their side
— Thomas Lymes

“Citizen science should have an explicit mention in the new directive as an awareness-raising tool,” Lymes insists. He points to examples of less popular air-quality interventions, like low-emission zones, which need citizen support in order to succeed: “For cities to do all that they need to improve air quality, they will need to pull out all the stops, and they need regular people on their side.”

The revised Air Quality Directive will go to the vote for amendments in June 2023 . You can read Eurocities’ full proposal for amendments that will make the directive city-fit and effective here. Cities are still holding out hope for a directive that will allow them to effectively tackle air pollution and help local people and visitors lead full and healthy lives.


The quality of the air in our cities, and measures cities can take to improve it are key to slowing climate change and solving related problems like the energy crisis, noise pollution, biodiversity loss and the provision of green spaces. All of these topics will be key to discussions at the Eurocities Environment Forum 2023, ‘Powering our Cities,’ to be held in Ghent from 26-28 April.