review of the national air pollution control programme slovenia · 2020. 10. 12. · review of the...

Review of the National Air Pollution Control Programme – Slovenia

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

ED 11495 | Issue Number 5 | Date 01/10/2020

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

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Author:

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Natalia Anderson

Date:

01 October 2020

Ricardo Energy & Environment reference:

Ref: ED11495 - Issue Number 5

Review of the National Air Pollution Control Programme – Slovenia | 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) .................. 18

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

2030, intermediate emission levels for 2025 and stakeholder consultation (M, O) .................... 19

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

implementation and review and responsible competent authority (M, O) .................................. 21

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

environment and associated uncertainties (where applicable) (M, O) ....................................... 23

4 Conclusions and recommendations ....................................................................... 26

Conclusions ..................................................................................................................... 26

Recommendations .......................................................................................................... 27

Appendices

Appendix 1 Completeness assessment

Appendix 2 Assessment of the risk of non-compliance

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



Abbreviations

BaP Benzo(a)pyrene

BAT Best Available Technique

BC Black Carbon

CH4 Methane

CO2 Carbon dioxide

EEA European Environment Agency

Eionet The European Environment Information and Observation Network

EU European Union

GHG Greenhouse Gas

kt Kilo tonne

NAPCP National Air Pollution Control Programme

NECD National Emissions Ceiling Directive

NECP National Energy and Climate Plans

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 – Slovenia | 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) for Slovenia. A draft NAPCP was provided by the European Commission on 20 June 2019 for the purpose of the review. A final NAPCP was submitted on 10 October 2019 and the review was amended to reflect this final submission.

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 risk 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 NAPCP and robustness of the data provided.

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.

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 Member States are reliant on additional PaMs (as included in the ‘With

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

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

it provides that 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 Directive

objectives and; 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 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 draft NAPCP was provided by the European Commission for the purpose of the review on 20 June 2019. The final NAPCP was uploaded to the European Environment Information and Observation Network (Eionet)4 on 10 October 2019.

Was the common format used? Partially Slovenia does not use the common format but the headings for the respective sections are the same.

What is the length of the NAPCP? 70 pages

What language is the NAPCP reported in? Slovenian An official translation is published by the European Commission5.

What language is the supporting documentation reported in?

Not applicable Supporting documentation was not submitted.

How many external documents are referenced or provided in the NAPCP?

Six Weblinks were provided for six external data sources.

Is it possible to identify the required information in the external documents (i.e. is the page and chapter reference provided)?

No

Slovenia does not include page or chapter numbers in the references provided and web pages are not specified for the weblinks provided.

Can all external documents be accessed? Yes The weblinks provided are to publicly available websites.

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

States. The results show a few gaps in Member State reporting mainly related to information presented

for additional PaMs, as presented in Appendix 1 to this review. To summarise, the NAPCP for Slovenia

includes the minimum content required for:

Policy priorities for emission reductions and other relevant policy priorities and the responsible

authorities involved.

Progress made by current PaMs in reducing emissions and improving air quality, and the current

transboundary impact of national emission sources.

4 Eionet: Reporting obligation for: National Emission Ceiling Directive (NECD) - National air pollution control programmes. URL:

https://rod.eionet.europa.eu/obligations/753 [last accessed 20 December 2019].

5 https://ec.europa.eu/environment/air/reduction/NAPCP.htm

https://rod.eionet.europa.eu/obligations/753

https://ec.europa.eu/environment/air/reduction/NAPCP.htm




NAPCP projections of emissions and emission reductions with existing measures and their

projected impact on improving air quality.

Limited information is presented on the additional PaMs considered to comply with the emission

reduction commitments.

Information on the adopted measures listed in Annex III Part 2 to Directive (EU) 2016/2284 targeting the agricultural sector to comply with the emission reduction commitments.

Limited information is presented for the additional PaMs selected for adoption. Relevant air quality, energy and transport policies and programmes are presented for these PaMs.

NAPCP projections to show projected attainment of emission reduction commitments (WAM) and

an overview of the flexibilities used.

Gaps in the reporting of minimum content are:

Detail for the relevant policy priorities in industry is missing.

The year of the NAPCP projections is not presented for the NAPCP projections (for both the WM

and WAM scenarios).

Estimated emission reductions are not reported and no information is provided to show the

expected impacts on air quality and the environment of the PaMs considered.

Limited information is presented for the additional PaMs selected for adoption. No assessment of how selected PaMs ensure coherence with air quality objectives or with other relevant plans and programmes is presented in the NAPCP.

Optional content is provided as follows:

An executive summary.

Competent authorities responsible for source sectors.

The use of graphics to portray current progress achieved and projected impact on air quality

improvements.

An account of the uncertainties associated with the NAPCP projections under the WM scenario.

Additional details concerning the optional measures from Annex III Part 2 to Directive (EU)

2016/2284 targeting the agricultural sector to comply with the emission reduction commitments.

A qualitative description of the expected impact (under the WAM scenario) on PM2.5, PM10 and NO2

concentrations by 2030.




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)

The NAPCP projections with existing measures (WM scenario) show that Slovenia is projected

to achieve its 2020-2029 national commitments for all five NECD pollutants. Under the WM

scenario, for 2030 onwards, NMVOC and PM2.5 commitments are projected to be missed. SO2,

NOX and NH3 commitments are projected to be achieved.

According to the NAPCP projections with additional measures (WAM), Slovenia is projected to

achieve greater emission reductions for all NECD pollutants except SO2 for which, emission

levels are projected to remain the same compared to the WM scenario. Despite the greater

emission reductions, the projected emission reductions under WAM scenario are insufficient for

Slovenia to meet the 2030 onwards NMVOC and PM2.5 commitments.

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

in their NAPCP. The projections in the NAPCP are different to the projections submitted separately by

Slovenia under Article 10(2) of the Directive on 13 March 2019. Both use 2017 inventory data to

underpin the projections (as the latest historic year). The differences between the two sets of projections




do not materially affect the projected compliance with the emission reduction commitments except in

the case of SO2 and NOx, as described at the end of this section.

Table 5 of the NAPCP “Projections with measures by 2030 and emission reductions compared to 2030

targets” reports total emissions (in kt) for 2005, as well as 2017, 2020, 2025 and 2030. It also presents

reductions in emissions that are projected in the future years, expressed as a percentage of 2005

emissions. All figures in the table are rounded either to zero or one decimal point. When 2020 emission

reductions for NOx expressed as a percentage of 2005 reductions are rounded and then compared to

the respective 2020-29 emission reduction commitment, the analysis suggests that the commitment is

achieved. Indeed section 4.1.2 of the NAPCP states “Total projected NOx emissions in 2020 are 32.4

kt and 18.1 kt in 2030. Compared to 2005, this represents a decrease of 39 % and 66 % respectively,

and these are exactly the reductions required to achieve the objectives”. However, if the reductions are

not rounded, the analysis shows that the commitment is actually projected to be missed with a margin

of 0.48 percentage points. To validate these findings, the review team has also assessed Slovenia’s

projected compliance according to Article 10(2) projections. According to the Article 10(2) projections,

Slovenia projects to miss the 2020-29 commitment for NOx. It is clear therefore that the conclusions

drawn in the NAPCP on the Slovenia’s projected compliance with NOx 2020-29 emission reductions

commitment are incorrect. The same discrepancy has been noted for SO2 2030 onwards emission

reduction commitment. The rounding of emission reductions suggests that the commitment will be

achieved exactly, with no margin. Without the rounding, the commitment would be missed by 0.42

percentage points. As the projected emissions for SO2 are the same under WM and WAM scenarios

presented in the NAPCP, the same discrepancy is also noted for this pollutant in the WAM scenario for

2030.

In addition, the review has found that emission reductions for PM2.5 presented in Table 5 of the NAPCP

are incorrect. Instead of 31% reduction in 2020, it should be 28% and instead of 52% in 2020, it should

be 50%. This error is corrected in section 4.1.4 of the NAPCP which describes historical and future

trends in emissions of PM2.5. These differences however do not affect conclusions on compliance with

PM2.5 emission reduction commitments.

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 Slovenia 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

25 percentage points.

NOX – The projections of NOX emissions under the WM scenario show that Slovenia cannot comply


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

0.48 percentage points. However, the NAPCP states that the commitment will be achieved exactly,

with no margin.

NMVOC – The projections of NMVOC emissions under the WM scenario show that Slovenia 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 19 percentage points.




NH3 – The projections of NH3 emissions under the WM scenario show that Slovenia can comply




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




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 Slovenia 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 0.42 percentage points. However, the NAPCP states that the commitment will be

achieved exactly, with no margin.

NOX – The projections of NOX emissions under the WM scenario show that Slovenia can comply



margin of 1 percentage point.

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

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

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

missed with a margin of 8 percentage points.

NH3 – The projections of NH3 emissions under the WM scenario show that Slovenia can comply



margin of 1 percentage point.

PM2.5 – The projections of PM2.5 emissions under the WM scenario show that Slovenia 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 8 percentage point.




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 the commitment is projected to be missed.

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 Slovenia 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 Slovenia can comply




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




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







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

SO2 – The projections of SO2 emissions under the WM scenario show that Slovenia 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 0.42 percentage point. However, the NAPCP states that the commitment will be achieved

exactly, with no margin.

NOX – The projections of NOX emissions under the WM scenario show that Slovenia can comply




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

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



NH3– The projections of NH3 emissions under the WM scenario show that Slovenia can comply



margin of 1% point.

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

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



Figure 2-3 Projected attainment of emission reduction commitments (WAM 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 the commitment is projected to be missed.

Differences between the projections in the NAPCP and those submitted separately under Article 10(2)

on 13 March 2019 are as follows:

The emission projections differ for all NECD pollutants between the NAPCP projections and those submitted under Article 10(2). However the differences only affect projected compliance for the NOx 2020-29 commitment and the SO2 2030 onwards commitment. In both cases, the differences occur because the projected emission reductions as a percentage of the 2005 baseline year are rounded up in the NAPCP projections but reported to two decimal points for the projections submitted under Article 10(2). This allows the projected percentage emission reductions to meet the percentage emission reduction commitments exactly according to the information presented in the NAPCP, while missing the respective commitments according to the projections submitted under Article 10(2).

The NAPCP projections include a WAM scenario which has not been submitted under Article 10(2).

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 10 October 2019, after the deadline of 1 April.

The common format was not used by Slovenia.

No information is provided on the consultation activities undertaken for the development of the

NAPCP.

The NAPCP does not adhere to the common format specified by the Commission Implementing

Decision (EU) 2018/1522, pursuant to Article 6 of the NECD. The NAPCP is made up of one main report

(66 pages) and is not accompanied by supporting documentation. Of the six external links provided, all

are in working order. External references are publicly available.

The final NAPCP was submitted on 10 October 2019, building on an earlier draft which was submitted

to the European Commission on 20 June 2019. The delay was indicated to be due to the need to

harmonise the programme with the National Energy and Climate Plan (NECP). PaMs were submitted

via the EEA PaM-tool on 25 November 2019.

Slovenia clearly indicates the title of the document and identifies the competent authority responsible

for it as the Ministry of Environment and Spatial Planning.

No website link is provided to access information on the consultation activities undertaken for the

NAPCP. It is unclear if any consultation activities have been undertaken. The transboundary impact of

air pollution is outlined in the NAPCP (section 3.3 of the NAPCP); however, there is no evidence of a

transboundary consultation being conducted.

Executive summary (O)

A two-page executive summary is provided (section 1 of the NAPCP). It does not follow the structure

of the common format but covers most of the suggested content (only a summary of the coherence

assessment is missing). In sum, the executive summary provided by Slovenia is structured as follows:

The emission commitments under the NECD.

The main sources of emissions.

The national policy framework (including the responsible authority).

Progress made with existing measures and identification for areas of non-compliance.

Planned additional measures.

Projections with additional measures.

The information in the executive summary is consistent with the content of the NAPCP.

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

Air quality policy priorities are presented for PM10.

The relevant climate change and energy policy priorities are described in the context of the

NECP, the National Renewables Action Plan and the Energy Efficiency Action Plan (section 2.1

of the NAPCP).

Agriculture, transport and development policy priorities are described in section 2.1.4.

An overview of all responsible authorities is provided in section 2.2.

Slovenia’s national air quality and pollution policy framework is presented in section 2 of the NAPCP,




Relevant policy priorities are described in Section 2.1. In sum:

Air quality policy priorities are presented for PM10 (section 2.1.2 of the NAPCP), referring to an air

quality plan for PM10 and an operational programme for the reduction of PM10 emissions. Slovenia

does not refer to the WHO guideline values for the air quality priorities described.

The EEA air quality country fact sheet6 indicates that there have been exceedances of the EU limit

and target values for PM10 and O3 in Slovenia. Beyond stating the corresponding EU legal

requirements, O3 is not described among the air quality priorities presented in the NAPCP.

The current policy priorities for climate change and energy are described in the context of the NECP,

which does not include the non-ETS GHG reduction target (section 2.1.3).

For renewable energy, the policy priorities are described in the context of the National Renewables

Action Plan (2010-2020), including the objective to achieve a 25% share of RES of final gross

energy consumption by 2020 (section 2.1.3).

Energy efficiency policy priorities are established by the national Energy Efficiency Action Plan

(2017-2020) and a Long-term Strategy for Promoting Energy Renovation in Buildings (section

2.1.3).

Relevant agriculture and transport policy priorities are set out in a National Development Strategy

2030 (section 2.1.4). Industry policy priorities are not covered.

In section 2.2 of the NAPCP, the responsible authorities are described in an overview table. The Ministry

of Environment and Spatial Planning has the primary responsibility for drafting legislation and

programmes on air pollution and air quality and has a coordinating role. In addition, regional and local

authorities also have a policy making role. Optional reporting concerning the responsible authorities for

specific source sectors is included in the table with reference to policy making (including the Ministry of

Infrastructure, the Ministry of Economic Development and Technology and the Ministry of Agriculture,

Food and Forestry). The Ministry of Health is also listed but it does not have a policy making role. The

NAPCP review finds that the role of the national government overseeing air pollution matters will

facilitate coordination between sectors and regions in implementation of the NAPCP. It also finds that

local involvement can strengthen implementation through more targeted action at a local level.

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

Progress made by current PaMs and EU policies in reducing emissions is described by pollutant.

The detail of the PaM description and their impacts, in terms of emission reductions, are not

presented consistently across all PaMs.

Drivers behind the emission reductions to date are described for: agriculture (NH3); energy

supply, industry and transport sectors (SO2, NOX and NMVOC); buildings (SO2 and NMVOC);

waste management and solvent use (NMVOC); and the energy consumption and transport

sectors (PM2.5).

Progress made in reducing emissions is described to varying degrees by pollutant (section 3.1 of the

NAPCP). Where provided, progress achieved by current PaMs is summarised by emission source

together with the timeframe in which progress has been achieved.

6 Air pollution country fact sheets 2018: https://www.eea.europa.eu/themes/air/country-fact-sheets [last accessed: 16/07/2019]




Drivers behind the emission reductions to date, including current PaMs and EU policies, have been

described with reference to their titles, relevant sectors (agriculture, buildings, households, industrial

processes, energy, transport and waste management) and affected pollutants.

PaMs and EU policies delivering SO2 emission reductions are described as:

2015 measures related to the Trbovlje and Šoštanj thermal power plants (Energy supply);

Application of the IPPC Directive introducing the requirement for installations to apply the Best

Available Techniques (BAT) and to introduce an environmental permit in 2007 (Industry);

Reduction of the sulphur content of liquid fuels (diesel, petrol, heating oil) in 2008 (Transport);

Measures to improve energy efficiency in all sectors, most notably in buildings; and

Measures to promote renewable energy sources.

PaMs and EU policies delivering NOX emission reductions are described as:

Implementation of primary measures on thermal power plants in the process of adapting to

emission limits for large energy installations and restructuring of the sector (Energy supply);

Tightening of Euro standards for new vehicles (Transport).

PaMs and EU policies delivering NMVOCs emission reductions are described as:

Decree on limit values for emissions of volatile organic compounds into the air from installations

using organic solvents (Industry);

Tightening of Euro standards for new vehicles (Transport);

Implementation of regulations on volatile organic compounds to air from petrol storage and transfer

petrol;

Reduction in the level of disposed waste (Waste);

Industrial restructuring and improving energy efficiency (Industry);

Improving energy efficiency in buildings.

PaMs and EU policies delivering NH3 emission reductions are described as:

Implementation of measures to reduce nitrogen losses in agriculture (Agriculture) - a list of

measures with reference to Annex III, Part 2 of the NECD is provided (detail is provided in section

3.7.1 of this review report).

PaMs and EU policies delivering PM2.5 emission reductions are described as:

2. Decrease in the share of households using wood biomass in old boilers: encouraging the

replacement of old boilers for wood with modern boilers, heat pumps, gas condensing boilers,

encouraging connection to district heating systems (Energy consumption);

3. Tightening of Euro standards for new vehicles (Transport).

Adding to this, existing PaMs and EU legislation that also contribute to reductions of GHG emissions

are presented in Annex 1 to the NAPCP. A total of 25 PaMs are described which were implemented

mainly between 2001 and 2011.

The impacts of the PaMs expressed in terms of the emission reduction achievements is not described

consistently. General emission trends are described for each of the pollutants in section 3.1 of the

NAPCP. Graphics are provided to illustrate emission reductions per pollutant and per sector (see

Figures 1 – 12 of the NAPCP).

3.4.2 Progress made by current PaMs in improving air quality

Table 2 in the NAPCP shows concentrations of NO2, O3, PM10 and PM2.5 in 2017, and indicates cases

of non-compliance with the limit value for PM10 and target value for O3.




Section 3.2 provides an overview of the challenges in relation to NO2, O3, PM10 and PM2.5, however,

current PaMs for improving air quality for the pollutants listed are not described within the NAPCP.

Charts are included in the NAPCP to illustrate air pollutant concentrations over a time series (2000-

2017 for O3 and 2002-2017 for PM10 and PM2.5). Maps are also included, illustrating the air quality

assessment zones (Figures 13-16 and Table 3 in the NAPCP).

3.4.3 Current transboundary impact of national emission sources

Section 3.3 of the NAPCP provides a quantitative overview of pollutant emissions from Slovenia

affecting neighbouring countries. Figures are provided for SO2, NOX and NH3 emissions (see Figures

17 – 20 of the NAPCP). The analysis has been produced by the Norwegian Meteorological Institute for

the year 2016 and shows that emissions with a transboundary effect have been decreasing since 2000,

in particular emissions of SO2. The maps show that affected countries include Czech Republic, Austria,

Hungary, Italy, Croatia, Poland, Germany, Lithuania, Belarus, Ukraine, Romania, Serbia and Bosnia

and Herzegovina.

There is no evidence of transboundary consultation activities being undertaken in the development of

the NAPCP.

Projected situation assuming no change in currently adopted

PaMs (M, O)

Under the WM scenario, all 2020-2029 emission reduction commitments are projected to be

achieved. The 2030 onwards commitments for NMVOC and PM2.5 are projected to be missed.

SO2, NOX and NH3 commitments are projected to be achieved (Table 4, section 4.1 of the

NAPCP).

Projected impacts on air quality improvements is provided in qualitative terms for NO2, PM2.5 and

PM10 up to 2030 (section 4.2 of the NAPCP).

In section 4.1 of the NAPCP, Slovenia provides an overview of the emissions reductions projected

under WM scenario reported for 2020, 2025 and 2030 and whether it meets the national emission

reduction commitment set in the NECD. In sum:

All 2020-2029 emission reduction commitments are projected to be achieved.

2030 onwards commitments for NMVOC and PM2.5 are projected to be missed with existing

measures (by 4 and 3 percentage points, respectively).

2030 onwards commitments for SO2, NOX and NH3 are projected to be met by 1 percentage point

or less.

As presented in section 2 of this report, the inventory year underpinning the projections is reported

(2017), but the year that the NAPCP projections were produced is not. However, based on the year of

the inventory data underpinning the projections, the NAPCP projections are judged in the review as

sufficiently up to date to reflect existing PaMs in the WM scenario.

With regards to air quality improvements, Slovenia shows the projected improvements in air quality for

NO2, PM2.5 and PM10 as percentage reductions of pollutant concentrations modelled for the year 2030

(section 4.2). Information is not presented for ground-level O3, despite the fact that incidences of non-

compliance are reported for O3 in 2017. The projected impacts on air quality are not described with

respect to the degree of compliance with EU air quality standards.




Policy options considered to comply with emission reduction

commitments for 2020 and 2030, intermediate emission

levels for 2025 and stakeholder consultation (M, O)

PaMs were submitted via the EEA PaM-tool on 25 November 2019. Information is also presented

in section 5 of the NAPCP.

13 PaMs (1 package of 5 individual PaMs and 8 individual PaMs) are considered to deliver

emission reductions from energy consumption, the transport sector and solvent use. The PaMs

will primarily reduce NMVOC and PM2.5 emissions. These are the pollutants for which 2030

onwards commitments are projected to be missed with existing measures.

Information is not provided for the expected quantified impacts of the PaMs on air pollutant

emissions, air quality and the environment.

3.6.1 Summary of the information reported

PaMs were submitted via the EEA PaM-tool on 25 November 2019. Information is also presented in

section 5 of the NAPCP. The assessment presented in this section is based on the information

submitted via the EEA-PaM tool as well as accompanying information reported in the main body of the

NAPCP.

Limited information is reported via the EEA PaM-tool. A total of 13 PaMs are considered for adoption:

seven relate to the combustion of wood, three to the transport sector and two to solvent use, as listed

below.

Limited information is also presented in the NAPCP. For each of the PaMs, information is provided as

follows: i) name and short description, ii) pollutants concerned, iii) objectives, iv) types of PaMs, v)

sectors concerned, vi) implementation period; vii) responsible authority; and viii) reference to planning

documents underlying the PaM.

In view of the limited information presented (the emission reductions are not quantified for individual or

packages of PaMs and the PaM description is brief), the PaMs are judged by the reviewers as not

credible. It is not feasible to confidently comment on whether the projected impacts on emissions are

realistic and achievable.

The PaMs considered are presented in the tables below, all have been selected for adoption.

Energy consumption (three individual PaMs and one package of five PaMs)

Reducing emissions from wood biomass boilers in households

More intensive promotion of replacement of old wood biomass combustion plants with modern wood

biomass installations (Eco label) or heat pumps

Restrictions on the sale of inefficient wood biomass installations, installation of a new plant by a

certified provider, with a mandatory demonstration of proper use of newly fitted equipment

Establish conditions for the professional functioning of chimney sweeping services, to introduce

professional supervision of the work of chimney sweeping services, to organise complementary

training courses for chimney sweeps

Awareness-raising and education of users of woody biomass devices in relation to adequate fuel and

proper burning, consequences of misfiring by using different communication channels

Demonstration projects of proper burning




Energy consumption (three individual PaMs and one package of five PaMs)

Individual PaMs

Preparation of a programme to exchange devices and raise awareness among households of socially

weak households about the correct use of wood biomass installations

Incentives to install particulate filters on small combustion plants

Promoting the connection to district heating systems and the construction of small systems in areas

where forest cover is high

Transport (three individual PaMs)

Strengthening the incentives in the field of alternative powertrains in line with the alternative transport

action programme

Green areas in cities where only zero emission vehicles are allowed, including delivery vehicles and

buses.

Incentives for modal shift through the preparation of institutions’ mobility plans, reward for the use of

public passenger transport or non-motorised transport modes in organisations

Solvent use (two individual PaMs)

Improvement of the recording of emissions from the domestic solvents use (NFR code 2.D.3.a)

Collection of records for all chemicals

Notes: All PaMs considered have been selected for adoption.

3.6.2 Pollutants targeted and projected emission reductions

Section 5 of the NAPCP re-iterates the non-compliance projected for NMVOC and PM2.5 2030 onwards

commitments with existing measures and highlights that additional PaMs are needed to meet emission

reduction commitments.

According to the reporting via the EEA PaM-tool, PaMs target emission reductions of PM2.5 and

NMVOC. PaMs targeting the transport sector will also deliver emission reductions of NOX.

Information on the estimated quantified effect of the PaMs is not reported via the EEA PaM-tool or

presented in the NAPCP.

3.6.3 Coherence between the PaMs considered and policy priorities

Coherence between the additional PaMs and policy priorities is not reported via the EEA PaM-tool or


3.6.4 Responsible authorities and timescales for implementation of PaMs considered

There is a good mixture of economic, regulatory, awareness raising, pollution control and planning

policy tools across the listed PaMs.

Implementation of the 13 additional PaMs considered would be overseen by a mixture of authorities,

including the Ministry of the Environment and Spatial Planning, the Ministry of Infrastructure and the




Ecological Fund and the Statistical Office. As indicated in section 3.3, the Ministry of Environment and

Spatial Planning has an overall coordination role.

Planned implementation is scheduled to start in 2020 and finish in 2030 for all the PaMs considered.

3.6.5 Details of the methodology for evaluation and selection of PaMs

There is no information on the methodology for evaluation and selection of PaMs reported via the EEA

PaM-tool or presented in the NAPCP.

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

considered

No information is provided on the costs and benefits of the additional PaMs reported via the EEA PaM-

tool or presented in the NAPCP.

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

PaMs considered

Despite non-compliance with air quality standards for O3 and PM10 (see section 3.4.2 of this review

report), the impacts of additional PaMs considered on air quality improvements for these pollutants are

not reported via the EEA PaM-tool or presented in the NAPCP (either in relation to EU air quality

standards or the WHO air quality guidelines).

The policies selected for adoption by sector including

timetable for adoption, implementation and review and

responsible competent authority (M, O)

All PaMs have been selected for adoption according to the information presented in the NAPCP.

With the additional PaMs, Slovenia is nonetheless still projecting to miss the 2030 onwards

commitments for NMVOC and PM2.5.

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

According to the information presented in the NAPCP, Slovenia has selected 13 PaMs for adoption. No

explanation of the choices made to select the PaMs is provided. According to reporting via the EEA

PaM-tool, none of the additional PaMs have been selected for adoption. It is unclear why this

discrepancy in reporting has occurred based on the information available in the NAPCP and via the

EEA PaM-tool.

The estimated emission reductions for these PaMs is not presented in the NAPCP. Furthermore, no

information is presented on how progress in implementation will be monitored, with no indicators or

targets defined. The PaMs selected for adoption will be implemented by national government and

municipal authorities together with support from local stakeholders including media agencies, fire

services and other professional associations.

The PaMs selected for adoption are discussed per sector below with reference to the information

presented in section 5 of the NAPCP as well as the information reported via the EEA PaM-tool.

Agriculture

Information concerning measures relating to agriculture, as listed in Part 2 of Annex III of the NECD are

included in the NAPCP showing that all mandatory measures and a set of optional measures are

existing PaMs in Slovenia (sections 3.1.4 and 5.2 of the NAPCP).




An overview table provides information on the implementation of these measures (see Table 1 of the

NAPCP), including 1) National Advisory Code of Good Agricultural Practice for the Control of Ammonia

Emissions is drawn up by the State, 2) National nitrogen balances to monitor changes in total losses of

reactive nitrogen from agriculture, 3) Prohibition of the use of ammonium carbonate fertilisers and

reduction of ammonia emissions from fertilisation with mineral fertilisers and 4) Reduction of ammonia

emissions from the storage of livestock manure and fertilisation with livestock manure. For 3) and 4) a

list of PaMs is provided in the table.

No information is provided as to whether modifications have been made. No other agriculture related

PaMs targeting PM2.5 or black carbon are included in the NAPCP.

Energy consumption

PaMs cover energy consumption for domestic heating, relating to biomass boiler standards and their

use, as well as chimney sweeping services. PaMs also relate to access to district heating systems

and incentives to install particulate filters on small combustion plants.

For energy consumption, PaMs selected for adoption include a combination of policy instruments

(voluntary awareness raising campaigns, economic measures, regulatory intervention, and

monitoring). Based on the PaM descriptions, the NAPCP review finds that it is likely that this mix of

policy instruments can deliver emission reductions. Implementation is planned to start in 2020 and to

finish in 2030.

No emission reductions have been estimated for these PaMs. In accordance with the guidelines for

reporting PaMs in the EEA PaM-tool (2019)7, it is possible that estimated emission reductions have

not been reported for these PaMs because they are not intended to bring any emissions reduction by

themselves (i.e. emission reductions will only be achieved if standards are adhered to).

Transport

The limited description presented in the NAPCP for the individual PaM adopted to promote alternative

fuels means it is not possible to determine what this will entail. The other two PaMs selected for adoption

are aimed at supporting a modal shift from motorised modes of transport to non-motorised modes of

transport with the establishment of green areas in cities and other incentives.

PaMs selected for adoption to reduce emissions from transport include a combination of policy

instruments (economic, regulatory and fiscal measures, as well as awareness raising campaigns).

Implementation is planned to start in 2020 and to finish in 2030.

No emission reductions have been estimated for these PaMs.

Based on the descriptions of the PaMs targeting the transport sector, the NAPCP review finds that

these PaMs are more relevant to NOx emission reductions rather than PM2.5 (introducing mobility plans

to facilitate alternative fuels in transport and non-motorised transport).

Other

For solvent use, PaMs adopted relate to monitoring and reporting of emissions from the domestic

solvents use. It is unclear from the information presented how the PaMs will deliver emission

reductions. Implementation is planned to start in 2020 and to finish in 2030.

No emission reductions have been estimated for these PaMs. In accordance with the guidelines for

reporting PaMs in the EEA PaM-tool (2019)7, it is possible that estimated emission reductions have

not been reported for these PaMs because they are not intended to bring any emissions reduction by

themselves.

7 Aether and EEA (2019) Guidelines for reporting Policies and Measures in the EEA PAM-tool, under Directive (EU) 2016/2284 on the reduction of

national emissions of certain atmospheric pollutants (NEC Directive). http://cdr.eionet.europa.eu/help/necd/necd_guide_2019.pdf

http://cdr.eionet.europa.eu/help/necd/necd_guide_2019.pdf




3.7.2 Feedback from the consultation undertaken

Slovenia does not report any views from the consultation with respect to the final selection and design

of the PaMs selected for adoption.

3.7.3 Sources of funding

No information on funding sources is reported in the NAPCP.

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

For each of the PaMs selected for adoption, the underlying planning documents are reported which

establish coherence with air quality policy priorities (and related air quality plans) and other policies for

energy and transport (and related action plans). However, no further detail is provided.

Projected combined impacts of PaMs on emission

reductions, air quality and the environment and associated

uncertainties (where applicable) (M, O)

Under a WAM scenario, the 2030 onwards commitments for NMVOC and PM2.5 are projected

to be missed (section 6.1 of the NAPCP).

The emission projections provided by Slovenia follow a linear emission reduction trajectory.

Adjustments to the historical inventory data have been applied to NMVOC and NOX from

agricultural sources.

Slovenia provides a qualitative description of the expected impact on PM2.5, PM10 and NO2

concentrations by 2030 which indicates that only minor improvements are projected compared

to the WM scenario.

Slovenia does not provide information concerning the projected impacts on the environment.

3.8.1 Likelihood of achievement of projected emission reductions

According to the projections presented in the NAPCP, emission reductions under the WAM scenario

are projected to achieve the 2020-29 national emission reduction commitments. For 2030 onwards,

Slovenia is projected to miss the commitments for NMVOC and PM2.5 (as presented in section 6.1,

Table 11 of the NAPCP and summarised in section 2.2 of this report).

Conclusions from the NAPCP review on whether the projected emission reductions per pollutant are

likely to realise 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 No

No additional PaMs are

considered or adopted for this

pollutant.

n/a

NOX Yes No




Do the PaMs selected for

adoption target the key emitting

sectors?

Are the projected emission reductions

for 2020 and 2030 likely to be

achieved?



pollutant according to the

information presented in the

NAPCP. According to information

reported via the EEA PaM-tool, the

PaMs targeting the transport

sector (introducing mobility plans

to facilitate alternative fuels in

transport and non-motorised

transport) are likely to also deliver

emission reductions of NOx.

For transport, the PaMs are intended

to support a modal shift, for which, the

estimated quantified impacts are not

presented in the NAPCP. Thus, it is

not possible to determine how likely

any emission reductions might be.

NMVOC Yes

Additional PaMs adopted target

the main sources of NMVOC

emissions which are solvent use

and energy consumption by

households (from burning of wood

biomass).

No

For solvent use, the PaMs rely on

monitoring and reporting of emissions

and there is uncertainty as to what

emission reductions this alone can

achieve.

For energy consumption, PaMs

adopted rely on the implementation of

standards to deliver emission

reductions.

In both cases, the estimated

quantified impacts are not presented

in the NAPCP. Thus, it is not possible

to determine how likely any emission

reductions might be.

NH3 No



pollutant.

n/a

PM2.5 Yes

PaMs adopted target combustion

of wood in energy consumption

and the transport sector as two

key emitting sources of PM2.5.

No

For transport, the PaMs are intended

to support a modal shift, for which, the

estimated quantified impacts are not

presented in the NAPCP. Thus, it is

not possible to determine how likely

any emission reductions might be.

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

The NAPCP emission projections provided by Slovenia follow a linear emission reduction trajectory.

3.8.3 Use of flexibilities

The NAPCP states that adjustments to the historical inventory data have been applied to NMVOC and

NOX from agricultural sources in accordance with point 1 of Article 5 of the NECD. However, no

explanation is reported and the information provided in the NAPCP does not fulfil the requirements by

Part 4 of Annex IV of the NECD.

3.8.4 Projected impacts on air quality and the environment.

Slovenia provides a qualitative description of the expected impact on PM2.5, PM10 and NO2

concentrations by 2030 (see section 6.3). This section shows that the impact under a WAM scenario

on air quality is very small. The SHERPA tool has been used to model impacts of projected emission

reductions on air quality.

In section 6.3 Slovenia provided three maps to illustrate projected reductions in NO2, PM2.5 and PM10

concentrations under the WAM scenario (Figures 29-31 in the NAPCP). There is no information

regarding compliance with the EU limit and target values.





4 Conclusions and recommendations

Conclusions

The NAPCP was submitted on 10 October 2019, after the reporting deadline of 1 April 2019. The

common format has not been used in terms of its layout and content. However, the NAPCP follows the

structure of the common format in most cases. PaMs were submitted via the EEA PaM-tool on 25

November 2019.

It was reported in the NAPCP that delays in finalising the NAPCP were necessary to ensure coherence

with the NECP which was being prepared at the time. However, it is not clear from the information

presented in the final NAPCP how the NECP has been taken into account.

The completeness assessment conducted identified a few gaps in reporting relating to the policy

priorities described, information on additional PaMs and for the NAPCP projections. According to the

NAPCP review, the significance of the gaps identified is as follows:

Overall, the limited information presented for the additional PaMs considered and selected for

adoption is the most significant gap. The NAPCP does not present the estimated emission

reductions, or the expected impacts on air quality and the environment of the PaMs.

The year of NAPCP projections is not reported.

The NAPCP projections under a WM scenario show that Slovenia is projected to achieve its 2020-2029

national emission reduction commitments for all five NECD pollutants, but for 2030 onwards, NMVOC

and PM2.5 commitments are projected to be missed. Accordingly, information on additional PaMs

targeting NMVOC and PM2.5 is presented in the NAPCP.

There are differences between the projections (WM scenario) submitted under Article 10(2) and the

projections (WM scenario) presented in the NAPCP. The differences affect the projected compliance

for the NOx 2020-29 commitment and the SO2 2030 onwards commitment. In both cases, the

differences occur because the projected emission reductions as a percentage of the 2005 baseline year

are rounded up in the NAPCP projections but reported to two decimal points for the projections

submitted under Article 10(2). This allows the projected percentage emission reductions to meet the

percentage emission reduction commitments exactly according to the information presented in the

NAPCP, while missing the respective commitments according to the projections submitted under Article

10(2).

Based on the projections presented in the NAPCP, additional PaMs are not considered necessary for

SO2 and NOx.

The contradicting information reported via the EEA PaM-tool and the information presented in the

NAPCP makes it unclear if the additional PaMs have been selected for adoption. According to the

NAPCP a total of 13 PaMs are selected for adoption, targeting NMVOC and PM2.5 emissions. The extent

to which the PaMs can be judged to be credible is limited based on the minimal descriptions presented

and lack of estimated emission reduction data. Even with additional PaMs, Slovenia is not expected to

meet the 2030 onwards commitments for NMVOC and PM2.5. Further additional PaMs are required to

ensure these commitments can be met.

A positive highlight from the review of the NAPCP is that much of the optional content is presented

together with a detailed account of existing PaMs. This includes:

The detailed description of existing PaMs and implemented EU legislation which provides a good

basis for understanding progress achieved to date in reducing emissions to air as well as improving

air quality (which are presented with references to related programming documents). The additional

detail in Annex 1 demonstrates coherence with energy and climate policy priorities for existing PaMs

adopted.




The use of graphics to portray current progress achieved and projected impact on air quality

improvements complements the detailed descriptions provided for existing PaMs.

Both existing and additional measures for agriculture listed in Annex III, Part 2 to the NECD are

reported in the NAPCP. This enables the NAPCP review to establish how mandatory measures in

the NECD have been adopted.

Additional PaMs are presented together with their respective underlying planning documents which

demonstrates how coherence with air quality policy priorities and relevant energy and transport

policy priorities is intended to be achieved.

The projections under a WAM scenario were not submitted under Article 10(2). Thus, risk of non-

compliance (as presented in the risk assessment in Appendix 2 to this report) is determined according

to the Article 10(2) projections under a WM scenario. According to the risk assessment therefore,

Slovenia is at a high risk of non-compliance with 2020-29 NOx commitment and the 2030 onwards

commitments for SO2, NMVOC, NH3 and PM2.5. .

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

Slovenia is required to use the common format for presenting its NAPCP.

The NAPCP projections under a WAM scenario show that even under the WAM scenario 2030

commitments for NMVOC and PM2.5 are projected not to be met. Further additional PaMs should

be considered and selected for adoption to ensure that the respective commitments can be met.

The date of the NAPCP projections is not reported. Furthermore, the review uncovered differences

between them and the projections submitted under Article 10(2). To ensure compliance (and to help

explain the differences identified), the date of the NAPCP projections is required.

Estimated emission reductions are not reported for the PaMs considered and information is not

provided for the impact on air quality and the environment. To ensure compliance, Slovenia should

provide all minimum content for the PaMs considered.

Areas for improvement

In accordance with the NECD, where appropriate, transboundary consultations shall be conducted

(Article 6(6)). Member States should provide links to relevant website(s) on the consultation

undertaken (section 2.1.1. of the common format). Slovenia identifies transboundary air pollution

transfers with neighbouring countries. However, evidence is needed to show that consultation on

the NAPCP has been undertaken with the affected neighbouring countries or if no consultation has

been undertaken then on the reasons why.

Based on the emission reductions presented in the NAPCP for the WM scenario the 2020-29 NOx

commitment and the 2030 SO2 commitment are projected to be achieved. However the review has

found that if the emission reductions were not rounded to a zero decimal point, these commitments

would be missed. According to the conclusions of the review of Article 10(2) projections, these




emission reduction commitments are also projected to be missed. It is recommended that for future

revisions of the NAPCP Slovenia does not round the figures to zero decimal point and more

precisely draws conclusions on projected compliance or non-compliance. In addition it is

recommended that Slovenia adopts additional PaMs to increase the margin by which the respective

commitments for NOx and SO2 can be achieved.

Slovenia describes the projected improvements in air quality for NO2, PM2.5 and PM10 in 2030.

However, information could also be provided on ground-level O3 in view of the incidences of non-

compliance with the EU target values in 2017.

The contradicting information reported via the EEA PaM-tool and the information presented in the

NAPCP makes it unclear if the additional PaMs have been selected for adoption. It is recommended

that reporting is aligned to avoid uncertainty.

Encouragement

According to Annex I of Commission Implementing Decision (EU) 2018/1522, reference can be

made to the WHO air quality guidelines. This optional content could be presented in the NAPCP to

strengthen the policy priorities described.

Optional PaMs targeting NH3 in the agricultural sector as set out in Part 2, section A of Annex III to

the NECD are reported. However, this is not done for PM2.5 and black carbon (Part 2, section B).

Slovenia is encouraged to add this information.

Slovenia is encouraged to include details on costs and benefits of PaMs considered for adoption.

Slovenia reports on its use of flexibilities in section 6.2 indicating that it wishes to adjust historic

inventories. Optional content on the details of such adjustments and its impact on compliance could

be presented in the NAPCP.


Slovenia is encouraged to present this optional content (section 2.8.5 of the common format).




Appendix 1 Completeness assessment

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

content minimum content as required by the Commission Implementing Decision (EU) 2018/1522)8

laying down a common format of the NAPCP. 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 Amber

The title, date and responsible authority (the Ministry of Environment and Spatial Planning) are presented in the NAPCP. No website links are provided to access the NAPCP and supporting documentation online, including information on consultation(s).

2.3.1 Policy priorities and their

relationship to priorities set in other

relevant policy areas

Amber

Slovenia reports emission reduction policy priorities (section 2.1.1) and their relation to priorities set in air quality (section 2.1.2), climate change and energy (section 2.1.3), and agriculture and transport (section 2.1.4). Policy priorities for industry are not reported.

2.3.2 Responsibilities attributed to

national, regional and local authorities Green

Responsibilities attributed to authorities at all levels of governance are reported (section 2.2).

2.4.1 Progress made by current PaMs in

reducing emissions, and the degree of

compliance with national and Union

emission reduction obligations

Green

Progress by current PaMs is reported by pollutant (section 3.1). References are incomplete (titles, page and chapter numbers and weblinks are not provided).


improving air quality, and the degree of Green

Slovenia identifies challenges for air quality (section 3.2). Compliant air quality zones with EU air quality objectives are reported for NO2, O3, PM10 and PM2.5. References are

8 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.





format

RAG

Rating Explanation

compliance with national and Union air

quality obligations

incomplete (titles, page and chapter numbers and weblinks are not provided).

2.4.3 Where relevant, current

transboundary impact of national emission

sources

Green Slovenia describes the current transboundary impact of domestic emission sources for all NECD pollutants (section 3.3).

2.5.1 Projected emissions and emission

reductions (WM scenario) Amber

Emission projections have been reported for 2005 base year, 2020, 2025 and 2030, complete with the minimum content required (section 4.1). The date of the projections is not provided.

2.5.2 Projected impact on improving air

quality (WM scenario) Amber

Projected improvements in air quality for NO2, PM2.5 and PM10 in 2030 are described but not for O3. The projected degree of compliance with EU air quality standards is not presented. References are incomplete (titles, page and chapter numbers and weblinks are missing).

2.6.1 Details concerning the PaMs

considered in order to comply with the

emission reduction commitments

(reporting at PaM level)

Amber

The EEA PaM-tool has been used for reporting. Emission reductions from the PaMs considered for adoption are not quantified.

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

Red Impact on air quality and the environment is not reported in the NAPCP or via the EEA PaM-tool.

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


Green

Mandatory measures for agriculture sector as listed in Part 2 of Annex III of the NECD are already implemented according to the information presented in the NAPCP (section 5.2). More detail is provided for PaMs targeting NH3 emission reductions. (Table 1 in section 3.1.4 of the NAPCP). Accordingly, no information is reported via the EEA PaM-tool for these measures.

2.7.1 Individual PaMs or package of PaMs

selected for adoption and the competent

authorities responsible

Amber

Slovenia reports that all additional PaMs are selected for adoption (section 6 of the NAPCP). Information on additional PaMs selected for adoption is thus presented in the section 5 of the NAPCP.

However, reporting via the EEA PaM-tool states that none of the PaMs have been selected for adoption. Thus, it is unclear whether the PaMs have been selected or not.

2.7.2 Assessment of how selected PaMs

ensure coherence with plans and

programmes set up in other relevant

policy areas

Amber

Relevant air quality, energy and transport policies and programmes are presented for those PaMs selected for adoption, but no assessment of how selected PaMs ensure coherence with air quality objectives or with





format

RAG

Rating Explanation

other relevant plans and programmes is presented in the NAPCP.

2.8.1 Projected attainment of emission

reduction commitments (WAM) Amber

Emission projections have been reported for 2005 base year, 2020, 2025 and 2030, complete with the minimum content required (section 6.1). The date of the projections is not provided.

2.8.2 Non-linear emission reduction

trajectory N/A

The emissions projected by Slovenia expect to follow a linear emission reduction trajectory.

2.8.3 Flexibilities Green

Slovenia indicates that it will use the flexibility in accordance with the first point of Article 5 of the NECD on adjustment of historical inventory.

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 Green Slovenia provides a two-page executive summary (section 1).

2.3.1 Policy priorities and their

relationship to priorities set in other

relevant policy areas: Reference to WHO

guideline values

White

Slovenia does not refer to the WHO guideline values with respect to the air quality priorities reported.

2.3.2 Responsibilities attributed to

national, regional and local authorities:

Source sectors under the responsibility of

the authority

Green Slovenia reports where competent authorities are responsible for specific source sectors (section 2.2).


reducing emissions, and the degree of

compliance with national and Union

emission reduction obligations: Provision

of graphics

Green Graphics are used to illustrate emission reductions per pollutant and per sector.





format

RAG

Rating Explanation


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

Charts are used to illustrate progress over a timeseries. A map is used to illustrate the air quality zones. Concentrations of air quality pollutants are described in relation to specific air quality zones, but progress is not described for current PaMs.

2.4.3 Methodologies and data used to

show the current transboundary impact of

national emission sources

White The data source is provided but no additional description is included.

2.5.1 Associated uncertainties of the

projected emissions and emission

reductions (WM scenario)

Green Slovenia outlines the associated uncertainties for the WM projections by pollutant (section 4.1).

2.5.2 Quantitative data on the projected

impact on improving air quality (WM

scenario)

White Quantitative data to describe the projected degree of compliance with EU air quality objectives is not presented.

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

White Additional PaMs do not target pollutants beyond the scope of the NECD.

2.6.3 Estimation of costs and benefits of

the individual PaM or package of PaMs

considered in order to comply with the


White Information on costs and benefits is not reported.

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 for optional measures relating to agriculture listed in Part 2 of Annex III of the NECD is presented in Table 1 in section 3.1.4 of the NAPCP for NH3 emission reduction measures only. Accordingly, no information is reported via the EEA PaM-tool for these measures.

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

White No comments from the consultation are reported in the NAPCP. No interim targets or indicators are reported in the NAPCP.

2.7.2 Explanation of the choice of

selected measures White The reasons for the selection of PaMs is not


2.8.4 Projected improvement in air quality

(WAM) Green

Slovenia presents a qualitative description of the expected impact on PM2.5, PM10 and NO2 concentrations by 2030.





format

RAG

Rating Explanation

2.8.5 Projected impacts on the

environment (WAM) White

Information on the projected impacts of PaMs on the environment is not presented in the NAPCP.




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 Yes Yes

WAM NR NR NR NR NR

Are the projections

submitted under Article

10(2) considered to be of

good quality?

WM No Partially Partially Partially Partially

Are the NAPCP projections

consistent with the latest

projections submitted

under Article 10(2)?

WM Partially No Partially Partially Partially

WAM n/a NR n/a n/a NR

Does the NAPCP present

credible additional PaMs

selected for adoption?

WAM n/a No n/a n/a n/a

Is the margin of

compliance (percent of the

compliance threshold)

likely to ensure compliance

with the emission




WM Yes (67) No (-1) Yes (12) Yes (8) Yes (11)

WAM NR NR NR NR NR

Risk of non-compliance M H M M M

Additional comments on

high risk scores

The review has concluded that Slovenia is at a high risk of non-

compliance with the emission reduction commitments for NOX for

2020-2029. This is driven by:

Slovenia projecting non-compliance with the NOx emission reduction commitment under the WM scenario submitted under Article 10(2)




Lack of WAM scenario demonstrating how the commitment will be achieved.

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




WM No Yes No Yes No

WAM NR NR NR NR NR

Are the projections

submitted under Article

10(2) considered to be of

good quality?

WM No Partially Partially Partially Partially

Are the NAPCP projections

consistent with the latest

projections submitted

under Article 10(2)?

WM No Yes Partially Partially Partially

WAM NR n/a NR n/a NR

Does the NAPCP present

credible additional PaMs

selected for adoption?

WAM n/a No No n/a No

Is the margin of

compliance (percent of the

compliance threshold)

likely to ensure compliance

with the emission




WM No (-6) No (2) No (-35) No (2) No (-4)

WAM NR NR NR NR NR

Risk of non-compliance H M H H H

Additional comments on

high risk scores

The review has concluded that Slovenia is at a high risk of non-

compliance with the emission reduction commitments for SO2,

NMVOC, NH3 and PM2.5 for 2030 onwards.

For SO2, NMVOC and PM2.5 this is driven by:

Slovenia projecting to miss the emission reduction commitment according to the projections submitted under Article 10(2) under WM scenario

Lack of WAM scenario demonstrating how the commitment will be achieved.

For NH3, this is driven by:

Minor improvements to the projection’s methodology recommended in the review.




Minor inconsistencies between the projections reported under Article 10(2) and those presented in the NAPCP.

Small margin of compliance with the emission reduction commitment.

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