The role of modelling and FAIRMODE in the Directive review WG1 activity/discussion

1. The role of modelling and FAIRMODE in the Directive reviewWG1 activity/discussion FAIRMODE Forum for air quality modelling in Europe Bruce Rolstad Denby FAIRMODE 4th Plenary, Norrkjoping Sweden June 2011

2. Content Presentation of results from the request for information from FAIRMODE MS representatives concerning modelling and the Directive. Selected discussion topics based on request Other topics from the floor Open floor contribution and discussion Coffee Quality assurance and the Directive Selected discussion topics Summary

3. General request for information Subject Which element of the AQ Directive or reporting you are referring to (if in the AQ Directive) Description of the problem or identified need to improve the AQ Directive How the Commission replied to your queries (if you queried and they replied) The suggested changes or additions that would help clarify the AQ Directive

4. Responses to the survey

5. Summary survey (1) • Need for mandatory modelling requirements in the AQ Directive (DE, PT) • Description: • As long as modelling is not mandatory, for any application in the AQ Directive, then modelling will not be actively implemented by the MS due to the historical reliance on monitoring and financial limitations. • Solution: • Require that modelling be carried out as a mandatory part of reporting, particularly when in exceedance, but also when providing plans.

6. Summary survey (2) • Need for clarity in the AQ Directive text on when, how and what models will be applied (ES, DE) • Description: • Almost nowhere is there an indication of what an AQ model is. Not even in the text concerning planning is there explicit reference to models as being the tool for carrying out such planning activities. • Solution: • Models should be explicitly named in the AQ Directive in regard to their use in planning and forecasting activities. A concise minimal requirement of what a model needs to represent is required in the AQ Directive (e.g. photochemical reactions, transport, dispersion, scale of application, etc.)

7. Summary survey (3) • The AQ Directive quality objectives for models requires revision (BE, ES, DE, HR) • Description: • Almost all contributors agree that the model quality objectives are inadequate. The current quality objective appears simple but it remains unclear. In addition the quality objectives are valid only for assessment application, not for planning. • Solution: 1) A clear and testable quality objective 2) Set of quality objectives based on recommended scientific metrics 3) A clear methodology for the application of the quality objectives 4) Quality objectives for models used for planning applications

8. Summary survey (4) • Optimising monitoring networks when using modelling (DE, PT) • Description: • Reference is provided in the AQ Directive to the fact that monitoring may be reduced when modelling is implemented. This is often unclear as to when this may be done. In general what is actually required is an optimal combination of monitoring and modelling to achieve the aims of the AQ Directive. • Solution: • As a minimum, clarity on these aspects is required. Better would be to provide a condition and incentive for carrying out an ‘optimal assessment’, be it through monitoring and/or modelling, rather than relying exclusively on monitoring.

9. Summary survey (5) • Uncertainty when reporting exceedances (BE) • Description: • Currently in the AQ Directive it is necessary to report uncertainties of both the monitoring and modelling assessments but at no point in the AQ Directive is there an admission to what these uncertainties actually imply, i.e. that there is some probability that there is an exceedance, rather than a definite, yes or no. • Solution: • Explore the possibilities of included uncertainty assessment in the exceedance reporting that effectively deals with this aspect. Taking into account other types of legislation that use methods for dealing with probability and uncertainty.

10. Selected topics to address Clarity in the Directive text in regard to modelling Review and revision of the quality objectives, link to benchmarking Mandatory modelling requirements Motivate the optimal use of models and monitoring Improved reporting mechanisms and methods, link to benchmarking Clarify the role of FAIRMODE in regard to the Directive

11. Topics from the floor • There will be no revision of PM this time round • Provide a document on the application and uses of models, short and clear, outlining their importance For assessment, for network design, for planning for forecasting • Is there an exceedance if it is only detected by a model? Not when reporting • Is there an obligation to measure in a model predicted exceedance? Only through the obligation to measure in hotspots. • Which came first, the quality assured model or the legislated model?

12. Some small points to consider Member states are resistant to more obligations, more reporting or more imposed criteria Reporting should be simplified and streamlined rather than expanded and complicated The Commission and MS would probably like changes to the Directive to be minimal Any changes must be well founded and the repercussions of these changes need to be preemptively diagnosed. The current QO is sufficiently flexible as to be non-restrictive MS want to pay less not more

13. Directive model quality objectives (Annex I) Mathematical interpretation ‘The uncertainty for modelling is defined as the maximum deviation of the measured and calculated concentration levels for 90 % of individual monitoring points, over the period considered, by the limit value (or target value in the case of ozone), without taking into account the timing of the events. The uncertainty for modelling shall be interpreted as being applicable in the region of the appropriate limit value (or target value in the case of ozone). The fixed measurements that have to be selected for comparison with modelling results shall be representative of the scale covered by the model.’

14. Quality objectives

15. Discussion points on the Directive QO Are the current quality objectives in the Directive obtainable now and/or in the future for all relevant compounds? To what degree are they relevant as indicators of uncertainty for Directive applications? How can these objectives be improved so that they are useful, indicative and relevant for the applications in the Directive? Is a model still 'usable and reportable' even if it does not obtain the Directive QO's? In regard to planning, is a QO for ‘dynamic sensitivity’ required? Can reference be made in the Directive to ‘FAIRMODE specified criteria’ instead of explicit QO’s? Is it more realistic that FAIRMODE can influence the reporting, rather than the Directive itself?

16. Delta tool Is this method suitable for policy? Suitable for science? Asaptions suitable for both?

17. Summary FAIRMODE should continue with the QA process and benchmarking currently ongoing The Directive QO are intended to be both clear and flexible. Are there some basic changes which will increase clarity and preserve flexibility?

18. http://fairmode.ew.eea.europa.eu/ For information and contributions contact Bruce Rolstad Denby bde@nilu.no

19. Comments from Tony Bush (AEAT) 3.1          This would be a significant additional burden to MS (if not UK) & would be a big step for the AQD, there is a lot opf supporting work on DQOs, uncertainties that would be required in advance of this. 3.2          Not sure how this helps, is it not the job of FAIRMODE to support this rather than the AQD 3.3          Yes, would tend to agree here but a method for testing the uncertainty of models to define achievable DQOs is need first 3.4          The ‘looseness’ of the existing AQD is beneficial as it enables optimised configuration based on individual MS needs. Tightening up would require another round of Article 5 assessment, costly 3.5          I think the AQD guidance is adequately clear in this respect, if models or measurements meeting the DQOs & show an exceedeance then there is one with the uncertainty envolope of the DQOs