POSITION PAPER on the revision of the Ambient Air Quality Directives

POSITION PAPER of environmental, health, children’s, women’s organisations and citizens’ groups in response to the public consultation ending 16.12.2021 on the revision of the Ambient Air Quality Directives (2008/50/EC – “the Directive” and 2004/107/EC)

We the undersigned 15 organisations and citizens’ groups from Bulgaria submit the following position paper in response to the public consultation on the revision of the Ambient Air Quality Directives (AAQDs) and in support of the efforts of the environmental umbrella NGOs in Brussels.

Air pollution is not only the number one environmental health risk in the 41 European countries with an estimated 440 000 premature deaths in 2019, but one of the leading environmental and health problems 1 in Bulgaria as well. With around 12 000 premature deaths relative to its smaller population Bulgaria is among the countries in the European Union suffering the most from air pollution. Air pollution causes both chronic and serious diseases such as asthma, cardiovascular problems and lung cancer.

Bulgaria is behind in meeting the current EU air quality standards and is still breaching the limit values for certain pollutants such as PM10, PM2.5, SO2 and NO2. As a result there has been a ruling from 2017 of the Court of Justice of the European Union on breaching PM10 limits and several pending infringements, including one on insufficient enforcement of the 2017 CJEU decision. Clearly Bulgaria has problems in implementing the clean air legislation since many of these limits had to be respected a decade ago.