a Partial year measurement (1/3 year) at only one station.
^b Threshold value (vegetation).
^c Running 8-hour average, highest each day.
^d Proposed EU limit value.
^e Non-overlapping 8-hour averages
^f Threshold value (human health)

The 1999 EU daughter directive also requires PM_2.5 (particulate matter less than 2.5 µm in diameter) to be measured and reported for representative locations, although limit values are not establish. Danish PM_2.5 measurements are being started in 2000 as part of the revised national air quality monitoring programme (LMP-IV).

Trends

The level of SO₂ in Denmark has been decreasing since it peaked in about 1984. The reduction is most evident for average values that are determined by the contributions from local sources. Average SO₂ concentrations have been reduced by almost a factor of five. Short-term statistics such as the 25th highest hour statistic, are more influenced by long-range transport episodes (NERI 1999).

Average NO₂ levels have been decreasing slightly since peaking in the late 1980's and early 1990's. The short-term statistics have been fairly constant after a weak maximum in the late 1980's. The 1998 annual average NO₂ levels at a traffic site in Copenhagen is slightly over the new EU limit value that must be met by 2005, while the short term NO₂ statistic (19^th highest hour) is well under the EU limit value.

Levels of total particulate matter (TSP) have been declining gradually since the late 1980's. TSP has been measured in Denmark since the 1970's, but PM₁₀ measurements began in 1998. Early results from PM₁₀ monitoring indicate that PM₁₀ levels are close to or slightly over the new EU limit values.

Benzene and CO concentrations have been falling in Copenhagen since measurements began in 1994, except for variations due to meteorological variability. This decline reflects the increasing number of cars with three-way catalysts. Benzene has fallen more sharply than CO due to the reduction of the benzene content in petrol from about 3.5% in 1995 to approx. 1% in 1998 (NERI, 1999).

Ozone levels show a declining trend since measurements began in 1992, although with considerable variation from year to year.

5.1.4 Human exposure

The total daily exposure of an individual to air pollution is the sum of the separate contacts to air pollution experienced by that individual as he/she passes through a series of environments during the course of the day: at home, while commuting, in the streets, etc. Exposures in each of these environments can be estimated as the product of the concentration of the pollutant and the time spent in the environment.

An ideal characterisation of the distribution of human exposures would be based on direct measurements of each pollutant concentration in the breathing zone of each member of a representative cross section of the population of interest. Such a programme is impractical if not technically impossible. Instead, ambient air quality measurements at central, fixed, air monitoring sites are widely used as substitute indicators of population exposures.

Measurement of daily average concentrations of a pollutant at a single, fixed-site outdoor monitoring point provides only a rough indicator of actual exposure, but these are generally the only widely available quantitative data that can be related to exposures. Some pollutants – for example ozone and fine particles (PM_2.5) – are comparatively evenly distributed across large areas and monitoring them at a limited number of sites may provide an adequate indication of concentrations over wide regions. On the other hand, concentrations of pollutants from traffic decline rapidly as one moves away from busy roads. Similarly, many industrial pollutants are localised near the industries that emit them.

Indoor exposures may be very different from that outdoors. Air pollutants emitted into outdoor air can be attenuated during infiltration into indoor air. This attenuation can be expected to be minimal for all pollutants of outdoor origin when barriers such as windows and doors are open or absent. In contrast, attenuation can be very large for tightly sealed buildings during times of maximal heating or cooling needs.

For relatively non-reactive gases like CO, or non-reactive fine particulate matter such as sulphate, indoor concentrations are usually near outdoor levels in homes without indoor sources. However, indoor concentrations can be much higher than outdoor concentrations when there are sources such as burning cigarettes and open flames used for cooking or space heating. Chemically reactive gases, such as O3 and SO2 react with interior surfaces, so indoor concentration are typically much lower than outdoor levels.

Concentrations of pollutants generated by motor vehicles may be significantly higher inside motor vehicles than average outdoor levels, and thus the motor car may itself be a significant microenvironment.

The levels of air pollution generally increase with increasing size of city or increasing traffic intensity. Levels generally decline going from city centre towards the suburbs and out into the countryside. About 1.8 million people in Denmark live in large urban areas, including about 1.5 million in the metropolitan Copenhagen area. Residents living along busy streets will be particularly exposed to pollutants emitted by traffic.

Lead and PAH are air pollutants that can gain access to humans through indirect transport routes. These other exposure routes dominate over inhalation exposure for these pollutants. Particles in exhaust containing lead or PAH deposited on terrestrial surfaces can be ingested; either directly from soil in play yards, or after being carried indoors as a component of house dust (especially for small children). Furthermore, particulate lead and PAH deposited on plants or agricultural fields can be retained in food products and add to body burdens. Dioxins are transported through the air, but the predominant exposure to dioxins is through the ingestion of food, especially from fish and fatty animal products in which dioxins tend to accumulate.

5.1.5 Health significance of air pollution

Inhalation of air pollutants is essentially unavoidable. Pollutants emitted into the atmosphere affect people when they are outdoors. Pollutants also infiltrate into homes, workplaces and vehicles, adding to pollutants emitted within those spaces, and contributing to peoples’ exposure around the clock.

It is very difficult to give precise quantitative information about the effects of air pollution on the Danish population because very little research has been done on this issue in Denmark. In other countries, especially in North America, knowledge about adverse health effects of air pollution has increased dramatically during the past ten years.

It is now generally agreed (from the majority of reviews and WHO assessments made in this field) that air pollution at the present level in Western Europe is expected to be associated with considerable adverse health effects in the human population. Air pollution has been found to be associated with increased morbidity and mortality determined by a variety of effects parameters such as the mortality rate, hospital admissions, occurrence of respiratory symptoms in the population, use of asthma medicine, decline in lung function, days absent from work or school, etc.

It is recognised that specific groups of the population are at risk, and especially in situations with high exposure or during episodes with increased levels of the air pollutants. From various studies the risk groups have been identified as people suffering from chronic respiratory diseases, people with cardiovascular diseases, elderly people, infants and children. Taken together, these groups make up quite a large percentage of the population. It should be noted that even at today's relatively low pollution levels – compared to former times –effects are expected to occur and primarily among the above mentioned risk groups.

An inter-ministerial task group was established in 1998 by the Ministry of Environment and Energy and the National Health Agency to assess the health implication of air pollution in Denmark, based on present knowledge, with special emphasis on the consequences of implementation of new and pro-posed EU limit values. Based on the evaluations of this task group, particles and ozone are considered to be the most critical air pollutants in Denmark in relation to health effects.

Particles

In recent years, increased focus has been placed on the adverse health effects of particles. Particles may be measured in different size fractions. The fine particle fraction PM_2.5 (particle diameter less than 2.5 microns) has been found to be the particle fraction most closely associated with adverse health effects in epidemiological studies. Table 5.4 and Table 5.5 show the dose-response relationships between particles and health effects from short-term and long-term exposure that were established in the WHO (1996) update of the air quality criteria for particulate matter.

Table 5.4
Associations between 3 days periods with mean PM₁₀ concentration of 50 and 100 µg/m³ and the increase in subjects (in a population of 1 million) experiencing health effects (WHO 1996)

Table 5.5
Summary of health response associations per 10 µg/m³ average long-term concentration of PM_2.5 (modified from WHO 1996).

The expert group of the WHO stated that no threshold could be determined for health effects associated with particulate matter. Comparing the dose-response associations given by the WHO with the present levels of particulates in Danish cities, it has been estimated that a 1/3-reduction of the annual average particle level in Danish cities (i.e. a reduction of about 15 µg/m³ TSP (total suspended particulates) corresponding to approximately 5 µg/m³ PM_2.5) would imply a decrease in annual mortality of about 400 deaths among 1 million people and a decrease of about 1,700 children suffering from bronchitis (MEM 2000a).

Ozone

Ozone is a strong oxidant causing respiratory symptoms, decline in lung function, increased airway responsiveness to irritants, and airway inflammation. Epidemiological studies have shown a relationship between ozone levels and respiratory symptom exacerbation among healthy children, adults and asthmatics corresponding to a 2.5% increase per 10 µg/m³ increase in the 8-hour average ozone level, together with a 2 % increase in hospital admissions due to respiratory conditions (WHO 1994).

Effects of ozone have been found down to levels below 100 µg/m³, but no exact lower threshold for adverse effects from ozone exposure has been identified. In Denmark, the 98-percentile for ozone levels is at about 100 µg/m³ and thus health effects from ozone exposure are to be expected in Denmark. Children, infants, elderly, ill and generally weakened persons are considered at special risk for adverse effects from ozone exposure. People spending much time outdoors (e.g. children), and people physically active outdoors are the most heavily exposed groups (MEM 2000b).

Dioxins

The emission of dioxins and dioxin-like PCBs is considered a problem in Denmark. Dioxins originate mainly from incineration and enter into the food chain after deposition on soil, crops, and in water. Recently (1999) WHO has set a health based tolerable daily intake value of 1-4 picogrammes TEQ (TCDD toxic equivalent) per kg bodyweight. In this year (2000) the Scientific Committee on Food has followed this up in the EU with a temporary value for tolerable weekly intake of 7 picogrammes TEQ per kg bodyweight. In the WHO evaluation it was stated that certain subtle effects may be occurring in some sections of the general populations of industrialised countries at current daily intake levels of 2-6 TEQ per kg bodyweight. In Denmark the Danish Veterinary and Food Administration has estimated an average daily human exposure of about 5 picogrammes TEQ per kg body-weight, i.e. a level above the tolerable levels given by the WHO and the Scientific Committee on Food. However, for the time being it is not clear whether or to which extent such an exposure level contribute to effects in the Danish population.

5.2 Level of protection

For unavoidable emissions to the air of harmful substances it is an overall aim that these must be handled in a way that human beings are not exposed to health hazards or nuisances, and animal and plant life are not harmed. With respect to health considerations this covers both protection from effects by direct inhalation and indirect effects from transmission of air pollutants to for example drinking water, soil and foodstuffs. The human protection also includes prevention against nuisances in the form of odours and dust. Furthermore, ecological considerations cover both direct effects on animal and plant life, and protection of the atmosphere against dangers, such as changes in the ozone layer.

The level of protection is primarily determined by use of health based guidance values or quality criteria, as well as the use of emission limits. The air quality criteria set by the Danish EPA are considered to represent a high level of protection. Further details on the scientific method for elaboration air quality criteria are given in Appendix 1.

5.2.1 Air quality norms

Extensive reviews of heath impacts of air pollution have been carried out recently by WHO (2000), based on methodologies established by WHO. The resulting WHO guidelines for air quality have formed the basis of the new EU daughter directives under the Framework Directive on Air Quality Management. Danish specialists have participated in the technical working groups preparing initial drafts for the directives.

The new EU daughter directives contain binding limit values for the member states, along with details on measurement and reporting requirements. These limit values are to be implemented in the national laws of the member states, including Denmark. Deadlines are set, for example 2005 or 2010, by which the limit values must be met.

The EU framework directive for air quality management requires preparation of daughter directives for the pollutants governed by existing EU ambient air quality directives, sulphur dioxide, nitrogen dioxide, particulate matter (PM₁₀ and PM_2.5), lead and ozone, plus the additional pollutants benzene, carbon monoxide, poly-aromatic hydrocarbons, cadmium, arsenic, nickel and mercury. A summary of EU ambient air quality limit values for the protection of human health is given in Appendix 3. The numerous other hazardous chemicals that are emitted into the air by industries and other sources will not have EU limit values in the foreseeable future. To regulate these industrial chemicals, the Danish EPA has established principles for determination of health based guidance values/ air quality criteria for specific chemical substances. These values are used to calculate the allowable emissions of chemical substances from industry and to calculate release heights (see Appendix 1).

The Danish principles for determination of health based guidance values for chemical substances involves review of the scientific research done on the possible harmful effects of a substance, in both epidemiological experiments and experiments with animals. From these data, the guidance value/quality criteria is set at a level considered not to cause any adverse effects in the population.

When the guidance values have been determined, they are used to derive specific statistical thresholds for practical regulatory use. These thresholds of pollutant concentration in the ambient air are known in Denmark as C-values (contribution values). A C-value is a limit value corresponding to a 99^th percentile statistic of measured hourly concentrations. This is a level that must not be exceeded more than about seven hours a month, or 1% of the time. The relationship between the health-based guidance value and the C-value depends on whether the health effect is acute (short-term) or chronic (long-term), and the uncertainty of the underlying data. The C-value is considered to reflect a high level of protection of human health, as the C-value in most cases is set equal to the health based guidance value.

After establishing acceptable emission amounts and concentrations from an industry, an atmospheric dispersion model is then used to determine the minimum release height (stack height) for the emissions. The model calculates hour by hour ambient concentrations of a pollutant over a year, based on emission rates and hour by hour meteorological data. The 99^th percentile statistic derived by the model is compared to the C-value for the pollutant. If the C-value is exceeded, the height of emission must be raised until the C-value is not exceeded.

A problem with limit values arises for air pollutants that do not have a lower threshold for health effects. Fine particulate matter is now recognised as a major health hazard in Danish cities. WHO (2000) was unable to identify a lower threshold for health effects of fine particulate matter (PM₁₀ and PM_2.5). Nonetheless, the first EU daughter directive specifies short-term and long-term limit values for PM₁₀ and permits the short-term limit value to be exceeded on up to 35 days per year. Present levels of PM₁₀ in urban areas in Denmark appear to be close to or somewhat over the new EU limit values. As shown in the previous section, a 1/3 reduction of annual PM_2.5 levels in Danish urban areas could be expected to result in about 400 fewer deaths per one million population per year (MEM 2000).

Ozone is another air pollutant without a lower threshold for health effects and a serious health hazard in Denmark. Clear and significant dose-response relations have been found in international studies for ozone concentrations between 40 and 200 µg/m³. Nonetheless, WHO (2000) has established a guideline value of 120 µg/m³ for 8-hour average concentrations, and this value is proposed to be used in a new EU daughter directive on ozone. As previously mentioned, ozone levels above the 100 µg/m³ level occur in Denmark and thus health effects from ozone exposure can be expected in Denmark.

For both fine particulate matter and ozone, the present level of regulatory protection is rather weak. The present levels of these pollutants, and the present limit values, imply tolerance of significant health impacts - even deaths - in the population. This is in stark contrast to the health-based regulation of water and soil pollution in Denmark, where any effect in the population is totally unacceptable. The outlook for fine particulate matter and ozone is not promising either. Both pollutants are very difficult to control, and their levels in Denmark depend significantly on transboundary air pollution transport. However, reduction measures for local sources of particulate matter may affect local population exposure to a great extent.

For dioxins it is similarly difficult to evaluate the degree of protection with regard to Danish dioxin emissions, since it is difficult to assess the contribution from Danish dioxin emissions to the current exposure of the Danish population. Nonetheless, a higher degree of protection and emission reductions are warranted as average exposure of the population is estimated to exceed the tolerable intake values of the WHO and the Scientific Committee of Food in the EU.

5.3 Regulation and strategy

Objectives and principles

International and EU co-operation and objectives

As mentioned above, ambient air pollution is transboundary. Long-distance transport of pollutants means that Danish air quality is partly the result of environmental regulation and management of sources in other countries. This makes international co-operation a significant part of the management of Denmark’s atmospheric environment. The major part of the national efforts in combating air pollution is done in EU and UN, including UN/ECE and UNEP.

EU legislation in this field is principally aimed at cutting emissions from industrial activities and road vehicles. Where transport is concerned, the strategy is:

	to reduce polluting emissions (catalytic converter, roadworthiness test);
	to reduce the fuel consumption of private cars (in collaboration with car manufacturers);
	to promote clean vehicles (tax incentives).

The EU legislation on the transport area concentrates on cars. Measures to combat air emissions from trucks, railways, aeroplanes and ships have been less intense and less systematic⁵⁵. Measures to reduce air emissions from cars have, since the early 1980’s, been prepared by the Commission’s Auto/Oil Programmes I and II.

There are several directives aiming at reducing emissions of air pollutants from industry. There are directives on emission limit values on combustion plants and on industrial installations. The IPPC-directive (96/61) is expected to result in a reduction of pollution, including air pollution, from heavy industries.

Air quality standards are advocated by Dir. 96/92/EC of 27 September 1996 on ambient air quality assessment and management (Air Quality Framework Directive) and by the subject of proposals of daughter directives under this Directive. The first daughter directive (1999/30/EC of 22 April 1999) relating to limit values for sulphur dioxide, oxides of nitrogen and nitrogen dioxide, particulate matters and lead in ambient air was adopted in 1999⁵⁶.

The major goals of the air quality directives are to provide a high level of protection for public health throughout the European Union, and to set ambient air quality limit values designed to protect the environment. The limit values are derived using the latest update of the WHO Air Quality Guidelines for Europe as a guide for the specific values.

The work and the objectives under the UN/ECE have primarily been linked to the 1979 Convention on Long-range Transboundary Air Pollution. The Convention was the first internationally legally binding instrument to deal with problems of air pollution on a broad regional basis. It was signed in 1979 and entered into force in 1983. It has created the essential framework for controlling and reducing the damage to human health and the environment of transboundary air pollution. Since its entry into force the Convention has been extended by eight protocols. The Community is a Party to the Convention and to some of its protocols.

Objectives and agreements concerning substances that deplete the ozone layer are commented in chapter 10 on chemicals.

National objectives and principles

Concrete Danish initiatives to reduce air pollution are very much based on UN/ECE and EU requirements for the reduction of certain pollutants and on air quality, and national objectives concerning air pollution related environmental problems such as acidification and eutrophication. The Danish strategy for air pollution is to fully implement the EU directives and UN agreements, and to work through EU and UN to lower the limit values and strengthen the provisions of the directives and the agreements.

The Danish efforts in reducing CO₂ emissions are based on the actions plans Energy 2000 (1990), Energy 21 (1996), Transport Action Plan (1990), Traffic 2005 (1993) and the Danish Government's Action Plan to Reduce the CO₂ Emissions of Transport (1995). Regulation is e.g. based on quota legislation.

The protection of air quality is based on e.g. legislation on fuel quality; legislation on sulphur taxes on fuel; quota legislation on limiting sulphur dioxides and nitrogen oxides from the electricity sector; legislation on catalysts on new cars.

Table 5.6
Danish objectives on air pollution

The NO_x objective has nearly been fulfilled; the reduction in 1998 compared to the level of 1986 was 28.5%.

5.3.1 Environmental objectives of industry

The industry sector, together with power generation, is a main contributor to the air pollution and is therefore in focus in general health, nature and environment policy efforts. The provisions of the Environmental Protection Act and Guidelines on Industrial Air Pollution Control regarding individual environmental regulation of enterprises, including the approval scheme⁵⁷ for the approximately 7,000 heavy polluters in Denmark, have proven an effective instrument for reducing the local environmental and health impact of industry. In recent years, direct legislative regulation of the sector has increasingly been supplemented by economic management tools and other tools such as environment labels, voluntary agreements and energy and environment management. The main objective of the Danish work concerning industry is to reduce air pollution as much as possible by:

	introducing BAT in all sectors
	making all industries comply with the C-values
	making industry produce cleaner products
	making industry work more actively with environmental management systems
	implementing the VOC-directive and by taking part in the making of new directives within the area
	laying down guiding limit values for all relevant substances. For dioxins these values will be published in 2001
	taking part in the preparation of BAT notes for relevant sectors
	making agreements on the reduction of emissions with the industry.

When deciding what is to be considered BAT, pollution must primarily be prevented by using cleaner technology (substitution, minimising the use of raw materials and energy, using closed systems etc.) and secondarily the unavoidable pollution must be minimised by using pollution preventing measures such as cleaning.

For SO₂ and NO_x clear reduction targets have been set. Industry shall contribute to the reduction of SO₂ emissions with 80% by the year 2000 compared to the emissions by the year 1988, and contribute to the reduction of NO_x emissions with 30% in 1998 compared to the emissions in 1985.

Other initiatives for the industry will be in pursuit of the general objectives and instruments for the integrated product policy, chemicals, Energy 21 and the Government’s waste plan 1998-2004 (Waste 21).

5.3.2 Environmental objectives of energy supply

The objectives on reducing air pollution from the energy supply mainly focus on emissions of SO₂, NO_x, heavy metals, (and CO₂). Emissions from heat and power production in Denmark are minimised and extensively controlled through fuel quality (sulphur content), combustion technology (low-NO_X burners, etc), filters, flue gas desulphurisation, NO_X control (selective catalytic reduction, etc.) and energy conservation.

The Government’s overall environmental goal on the energy area is to reduce the CO₂ emissions by 20% in 2005 compared to the level in 1998 and to reduce the emissions of other waste products significantly.

In order to attain these targets as well as a number of international goals, the Government drew up an energy action plan, Energy 21, in 1996. According to this plan, energy consumption must be stabilised while streamlining energy production and using renewable energy in the energy supply to a greater extent instead of fossil fuels. The intention is thus for renewable energy to account for 35% of the total energy consumption in 2030. A wide range of management tools is being used to implement this plan.

In March 1999 the Danish Parliament concluded an agreement regarding a new reform for the electricity area. According to this agreement, Denmark will be the first country to introduce a market for CO₂ quotas, which place an annual ceiling on the emission of CO₂ by the electricity sector. Furthermore, in future all electricity consumers must receive an increasing part of their power from renewable energy.

Regulation of the energy supply takes off in the acts on electricity, heating and natural gas supply. Further, it is supplied by a goal directed policy on subsidies, taxes and charges. Finally, there is a tradition for making agreements between the state and the energy sector. Agreements have been made on establishing windmills and the use of biomass.

5.3.3 Environmental objectives of transportation

Danish objectives on transport with relation to air pollution are laid down in the action plans Transport Action Plan, 1990, Traffic 2005, 1993, and the Danish Government's Action Plan to Reduce the CO₂ Emissions of Transport, 1996.

Controls on transportation emissions include fuel quality (lead, sulphur), emission standards for new vehicles (vehicle technology), inspection and maintenance, incentives to limit ownership and use of private vehicles, subsidies and incentives for public transportation, electrification of trains and buses (moves emissions to power plants).

Objectives with relation to air pollution, compared to 1988-levels, are:

	NOx and HC emissions are to be reduced with at least 40% before year 2000 and 60% before year 2010. Further reductions up to 2030 shall take place.
	Particulate matter emissions in the towns and cities shall be reduced with 50% before 2010. Further reductions up to 2030 shall take place.
	4% of transport by cars shall be replaced with bicycle or walk before 2005.

Air pollution (other than CO₂) from the transport sector has declined during recent years as a result of emission standards for new cars. However, the transport sector is not on a sustainable path. Negative impact on human health and environment is still a big issue.

In order to bring about more environmentally friendly goods transport, a panel was established in 1998 with participation of the transport sector and transport buyers, among others.

In order to limit environmental and health problems in the cities, the Government in 2000 granted the municipalities statutory authority to introduce experiments with traffic-regulating measures solely for environmental and health purposes, that is, areas where special environmental or health requirements may apply. Furthermore, promoting local plans for traffic and environment in the context of local Agenda 21, the regional and municipal planning and the urban political effort must support a sustainable transport policy at county and municipality level.

The Danish action plans on traffic, the EU-legislation and Danish environmental-traffic law have introduced a very complicated regulation system of the transport sector based on standards, norms, sector plans, physical plans and economic instruments. The Danish legislation to combat pollution from transportation in general reflects the EU initiatives taken. The legislation concentrates on cars.

5.3.4 Legislation on air pollution

Environmental Protection Act

Concrete regulation

Air pollution is under EPA regulated by concrete decisions such as environmental permits, prohibitions and orders under the act. Please refer to section 5.4.1 and 5.4.2 for a description of the environmental permit system and air pollution.

General regulation

The Minister has under the provisions of EPA published three orders of relevance to ambient air quality. Two orders on limit values for the content of SO₂ and particles and of NO₂ in ambient air⁵⁸. Both orders are to be amended as a result of the Danish implementation of the Air Quality Framework Directive and its daughter directives. Furthermore, there is order on monitoring and assessing the content of ozone in ambient air⁵⁹. The Order contains rules on monitoring and assessing the content of ozone in ambient air and for giving notice to the public when threshold values are exceeded⁶⁰.

The Minister has under the provisions of EPA published several Statutory Orders on reduction of air pollution from the industry, including from the heating industry, power plants and farms, including on emissions of asbestos; emissions of nitrogen dioxide, unburned hydrocarbons and carbon monoxide from gas engines and gas turbines; emissions of sulphur dioxide, nitrogen oxide and dust from power plants; the content of sulphur and other substances in fuel, which might cause pollution; the storage and treatment of farmyard manure and silage.

The most important regulations are:

	Order on approval etc. of waste combustion plants61. The order contains provisions that implement directive 94/97 on combustion of dangerous waste. It lays down rules on the establishment and running of a combustion plant for dangerous waste. Further, it requires the environmental authority to comply with the requirements on limit values, conditions and monitoring methods given under the Order when issuing environmental permits (waste combustion plants are subject to environmental permits).
	Order on waste combustion plants62. The order contains provisions that implement directive 89/369 and 89/429. The Order requires the environmental authority to comply with the requirements on limit values, conditions and monitoring methods given under the Order when issuing environmental permits (waste combustion plants are subject to environmental permits).
	Order on reduction of emissions of SO2, NOx and dust from large power plants63. The Order refers to directive 88/609. The Order lays down limit values, conditions and monitoring methods for large power plants.
	Order on reduction of emissions of asbestos to ambient air from industrial plants64. The Order refers to directive 87/217. The order lays down limit values, conditions and monitoring methods for industrial plants.

Several Danish statutory orders have been issued under the provisions of legislation administrated by the Ministry of Transport, but also under the provisions of EPA and Act on Chemical Substances and Products, mainly to implement EU legislation on (road) transport, including legislation on new vehicle emission standards⁶⁵; content of polluting substances, such as sulphur dioxide, in fuel; emissions from vapour and distribution of petrol; and inspection and maintenance.

The most important regulations are:

	Order on the quality of petrol and diesel oil for vehicles etc66. The Order contains provisions that implement directive 98/70. The Order lays down limit values for the content of a number of substances in petrol and diesel oil for vehicles.
	Order on environmental requirements when establishing and running a garage, etc67.
	Order on reduction of discharges of vapour when filling up the automobile tank with petrol68. The Order lays down rules on the establishment and running of installations to fill up the vehicle with petrol and diesel.
	Order on reduction of air polluting emissions from mobile off-roaders69. The Order contains provisions that implement directive 97/68. The Order lays down rules on labelling and marketing of engines for off-roaders.
	Order on reduction of discharges of vapour when storing and distributing petrol70. The Order contains provisions that implement directive 94/63. The Order lays down rules on establishment and running of terminals and gas stations with the aim of reducing loss of petrol by evaporation.

Act on Chemical Substances and Products

As mentioned above, also the Act on Chemical Substances and Products authorises the minister to lay down rules with the aim of protecting health and the environment.

The most important regulations are:

	Order on spraying with chemical substances from aeroplanes71;
	Order on the use of ozone depleting substances72. The Order prohibits the use of a number of ozone depleting substances.

5.4 Regulatory instruments

5.4.1 Guidelines/Norms

DEPA has issued two guidelines that are used as administrative and technical basis for laying down environmental conditions concerning air pollution in environmental permits and other administrative decisions (prohibitions and orders) under the Environmental Protection Act.

The most important guideline is Guidelines No. 6/1990 on Limitation of Industrial Air Pollution⁷³.

The Guidelines on Limitation of Industrial Air Pollution are based on the principles of e.g. replacement of air pollutants by other less critical substances; reduction of resource consumption and the use of less polluting production methods in enterprises; and employment of the best available technology. The authority shall take into consideration e.g. health – both direct health-related effects of air pollution and indirect pollution by the transfer of airborne substances into water and food – when laying down requirements to industry, etc. The Guidelines lay down limit values on emissions and ambient concentrations of a number of air polluting substances. The values are based on existing (at that time) knowledge on their harmful influence on health and environment. The principles for derivation of the health-based guidance values and the C-values, together with a table of the values of about 450 substances are given in appendix 1. The Guidelines are now being revised to clarify and simplify some procedures to ease the approval process. The revised Guidelines will clarify requirements for use of best available technology (BAT) and harmonise the guidelines with recent EU directives.

Furthermore, there is Guidelines no. 4/1985 on Industrial Odour Control, as nuisance from odour in some cases occur at lower levels compared to a level based on health protection, i.e. odour may in some cases be the most critical emission from an industrial plant.

As mentioned above, orders on approval etc. of waste combustion plants, and reduction of emissions of SO₂, NO_x and dust from large power plants⁷⁴ lay down rules on the establishment and running of waste and power plants, lay down limit values for emissions of a number of substances, and set up monitoring methods. The orders require the environmental authorities to comply with the provisions under the orders when making decisions under the Environmental Protection Act, for example when issuing environmental permits.

5.4.2 Approvals, etc.

As mentioned in chapter 3, section 3.5.2, certain types of polluting enterprises, plants or activities⁷⁵ - entered on the list on activities to be approved⁷⁶ - cannot be established or commenced without prior approval from the environmental authority. Such an approval is called environmental permit. Neither shall they be extended or modified without prior approval if those extensions or modifications will result in increased pollution.

The environmental permit includes the prior approval of air polluting emissions and might include conditions laid down with the aim of reducing air pollution.

Furthermore, under the EPA, the environmental authority is authorised to lay down requirements on industry etc., that are not subject to environmental permit, including laying down conditions for emissions and ambient concentrations of air polluting substances. The requirements are laid down in prohibitions and orders.

Air pollution reducing conditions under environmental permits or under prohibitions and orders are primarily based on Guidelines on Limitation of Industrial Air Pollution.

5.4.3 Environmental impact assessment

Some activities are subject to Environmental Impact Assessment. Activities subject to EIA are listed in Order no. 428 of 2 June 1999 on supplementing rules under the Planning Act. The assessment includes an assessment of the harmful health and environmental effects of substances emitted to air.

EIAs are used as planning instruments and as a basis for approvals, permits, etc. under the different environmental acts, such as EPA. A number of the enterprises that are subject to environmental permit (corresponds largely to the IPPC-enterprises under the IPPC-directive), are also subject to EIA (the EIA-list corresponds to the list under the EIA-directive). An environmental permit cannot be issued before the environmental authority has approved theEIA.

5.4.4 Monitoring instruments

The Danish National Environmental Research Institute (NERI)⁷⁷ is responsible for the two nation-wide air quality networks in Denmark - the urban network (LMP) and the background network (BOP).

LMP comprises an urban monitoring network with stations in three Danish cities (Copenhagen, Odense and Aalborg, and from 2000 also Aarhus). The results are used for assessment of the air pollution in Danish cities. Following substances are measured: NO, NO₂, SO₂, CO, O₃ , particles and heavy metals. The results are currently published in quarterly reports⁷⁸. A permanent smog warning system including NO₂ and O₃ was set up in 1994.

BOP assembles information on nutrient input to the aquatic systems. Measurement is performed at 8 different locations. These locations are selected to represent coastal and island based areas and inland areas. The samples are analysed for their content of nutrients and metal ions. Further-more, 7 stations are equipped with filter pack samplers to collect compounds in gas or in particle phase. The results are currently published in an annual report.

LMP has been revised in 2000 in order to fulfil the requirements to assess ambient air quality as laid down in Dir. 96/62/EC of 27 September 1996 on ambient air quality assessment and management (Air Quality Framework Directive) and the attached daughter directives.

The Air Quality Framework Directive requires Member States to ensure that a plan or programme is prepared for attaining the limit values within specific time limits in zones where levels are higher than the limit values. Further, it requires, in the event that the alert thresholds are exceeded, that Member States shall undertake to ensure that the necessary steps are taken to inform the public.

5.4.5 Planning instruments

Major power plants are regulated through county approvals on environmental impact assessments and environmental permits of the plants.

Traffic 2005 (1993) and the Danish Government's Action Plan to Reduce the CO₂ Emissions of Transport (1996); Energy 21 (1996), the Aquatic Environment Plans I and II (1987 and 1998) are all administrative planning instruments aiming at defining goals and instruments with the aim of combating air pollution.

5.4.6 Environmental agreements

In 1994, an environmental contract for reducing the emissions of VOCs was made between the Confederation of Danish Industries and the Minister. The character of the contract is primarily that of an action plan for the relevant branches. It is based on technical statements about the possible technical and economic barriers to reduction. For the industry the advantage of this contract lies precisely in the contract itself, as DEPA promised, already in 1989, not to raise the threshold limits for VOCs in air quality guidelines if the industry would prepare a plan for substantial reduction of VOC emissions by the year 2000.

5.4.7 Quotas

Emissions on SO₂ and NO_x are regulated through a quota system for the power plants. Every year the amount of permissible SO₂ and NO_x emissions is set up for the major power plants.

5.4.8 Economic instruments

For economic instruments aiming at reducing polluting emissions to air please refer to chapter 3. Product taxes/charges are laid down to reduce air pollution on vehicles, fuels and certain substances. There are taxes on the content of sulphur in fuels; annual vehicle taxes related to the level of air pollution from each type of vehicle; CFC tax; CO₂ tax; and tax on chlorinated solvents.

5.5 Actors

The primary actors concerning regulation of air pollution are listed in Table 5.7. For general descriptions of the mentioned actors please refer to chapter 3.

Table 5.7
Actors, roles and responsibilities concerning air pollution

5.6 Evaluation

The overall goal in relation to air quality is to achieve a quality without any adverse health effects to the public. Because of the present levels of air pollutants a more realistic objective of today, however, is to further reduce the levels of "classical air pollutants" in order to minimise any harmful impact on public health. For several pollutants it has not been possible to identify lower thresholds for effects e.g. for particulate matter and ozone as well as for carcinogens such as benzene and Benzo(a)pyrene. Based on international studies, the observed levels of fine particles (PM_2.5) and ozone in Denmark would imply significantly increased mortality and illness among sensitive groups: persons with existing respiratory illnesses and persons with heart disease. These groups make up a substantial fraction of the population. The level of these health impacts is only roughly estimated in Denmark, because there has been limited Danish research on this, and monitoring of fine particles has not even started in Denmark.

The average daily human exposure to dioxins in Denmark is also in recent Danish studies estimated to exceed the WHO guideline for tolerable daily intake, but is not clear to which extent such an exposure level contribute to effects in the Danish population.

That fact that current air pollution levels seems to imply significant health effects in the population indicates that the level of protection is considerably lower than for soil and water pollution. In these other media, limit values are set considerable below effects levels, and there are mandatory actions to remove the problem if limit values are exceeded. The EU framework directive on air quality management requires only planning to attain the ambient air quality limit values where they are exceeded, without specifying mandatory actions to take.

Reduction of fine particulate pollution will be a significant challenge in the coming years. The limited observations of PM₁₀ indicate that the EU limit values for PM_10, which will become effective in 2005 and 2010, are presently exceeded in Copenhagen. International experience indicates that particulate levels will be very difficult to reduce.

The occurrence of high ozone levels in Denmark is usually associated with transport of photochemical pollution from areas south of Denmark. Reduction of health impacts from ozone in Denmark will thus require a concerted effort throughout a large part of Europe. Fine particles are also transported long distances, which will also make control of fine particulate pollution in Denmark dependent on control in other countries.

Ultrafine particles have recently received a lot of attention in health impact research, and indications are that these tiny particles have a large impact on health. Research measurements of ultrafine particles have begun in Denmark, but there is not yet international consensus on standard measurement techniques for ultrafine particles. Further assessment of the effects of these particles is a challenge for the future.

There is a general trend of air pollution concentrations being lowered. Ambient levels of most of the primary air pollutants have been declining over the past decade due to improvements in energy production and the requirement of catalytic converters on new cars since 1990. However, the decline of NO₂ in urban areas has been rather weak, as the ozone concentration is the determining factor. The coming improvements in EU vehicle emission standards, fuel quality standards, plus required improvements at large industries in the EU, will continue to generally lower emissions, in spite of increasing vehicular traffic in Denmark.

It is generally accepted that industrial emissions of air pollutants is well regulated as the result of an effective approval (permit) system which has essentially achieved mandatory requirements for limitation of industrial emissions and the resulting ambient concentrations. The C-values and associated emission limits in this system have been established based on health risk assessments of each specific substance.

The new and planned EU air quality directives, and related vehicle, fuel and industrial directives, will establish consistent limit values for additional pollutants, and vehicle and large-industry requirements in all EU member states. These directives will provide continued reductions in the transboundary pollution that has health impacts in Denmark. The possibility and the need for further reduction of limit values should be regularly reviewed, as well as the need for limit values on additional pollutants, such as ultrafine particles.

It is vital to obtain a better characterisation of the different size fractions of ambient particulate pollution, and the exposure and impact on the population. There is also a need for increased knowledge of techniques for reduction of particle emissions from the various sources, such as filters on diesel vehicles. There is a need for further research on sources of dioxin and substances with similar properties and on the possibilities for further control and reduction of these pollutants.

5.7 References

Centers for Disease Control and Prevention (2000): "1,3-Butadiene ATSDR Fact Sheet" (http://aepo-xdv-www.epo.cdc.gov/wonder/
prevguid/p0000463-/p0000463.htm).

DEPA (1992): "Industrial Air Pollution Control Guidelines". Vejledning fra Miljøstyrelsen Nr. 9.

DEPA (1995): "Nationale og industrielle emissioner af 38 stoffer". (National and industrial emissions of 38 substances.) Working Report no. 64, Danish Environmental Protection Agency.

DEPA (2000): "Flow analysis for Dioxins in Denmark". by E. Hansen and S. Skårup. Environmental Project no. 570, Danish Environmental Protection Agency.

HEI (2000): "1,3-Butadiene: Cancer, Mutations, and Adducts". Research Report No. 92, by Rogene F. Henderson, Leslie Recio, Vernon E. Walker, Ian A. Blair, James A. Swenberg. Health Effects Institute (HEI), Cambridge, Massachusetts, March 2000, 234 pp. http://www.healtheffects.org/Pubs/Butadiene-S.pdf

Karsten Revsbech (1999): "Lærebog i miljøret" (Textbook in Environmental Law).

Ludwig Krämer (2000): "EC Environmental Law".

Larsen, P.B. et al. (1997): "Sundhedsmæssig vurdering af luftforurening fra vejtrafik" (Evaluation of the health impacts of air pollution from road traffic). Miljøprojekt nr. 352, Miljøstyrelsen.

Larsen, P.B. (1999): "Hvordan vurderer Miljøstyrelsen effekten af luftforurening" (How the Danish EPA assesses the effect of air pollution). Kontoret for Biocid- og Kemikalievurdering, Miljøstyrelsen. Paper presented at the IDA Meeting, 4 November 1999, 7 pp.

Ministry of Environment and Energy (1999): "The Danish Nature and Environment Policy".

Ministry of Environment and Energy (1993 and 1999): "EU, Denmark and the Environment", paper to be found on http://www.mst.dk/199909publikat/87-7909-412-0/helepubl.htm.

Ministry of Environment and Energy (1999): Natur- og Miljøpolitisk Redegørelse 1999, afsnit 15.1.3 Indeklima og luftforurening, Miljø- og Energiministeriet, http://www.mem.dk/publikationer/nmpr99/kapitel15.htm - 15.1.3.

Ministry of Environment and Energy (2000a): "Partikler" (Particles). Draft internal working paper of the Interministerial Working Group on Air Pollution, Ministry of Energy and Environment and the National Health Agency (Sundhedstyrelsen), 7 August 2000, 20 pages.

Ministry of Environment and Energy (2000b): "Ozon" [ozone]. Draft internal working paper of the Interministerial Working Group on Air Pollution ("luftgruppen"), Ministry of Energy and Environment and the National Health Agency (Sundhedstyrelsen), 8 August 2000, 14 pages.

Kemp, K, and F. Palmgren (1999): "The Danish Air Quality Monitoring Programme; Annual report for 1998". NERI Technical Report No. 296. National Environmental Research Institute.

NERI (2000): "The Danish Urban Air Quality Network" (LMP)  (http://www.dmu.dk/AtmosphericEnvironment/aq_besk/lmp.htm)

Finn Palmgren, Peter Wåhlin, Ruwim Berkowicz & Ole Hertel (1999): "Ultrafine partikler - luftforurening fra trafikken og befolkningseksponering". Paper presented at the conference Dansk Miljøforskning 1999.  (http://www.dmu.dk/miljoekonference1999/online/abstracts.htm)

Peter Wåhlin, Finn Palmgren and Rita van Dingenen (1999). Experimental Studies of Ultrafine Particles in Streets and the Relationship to Traffic. Poster presentation. Presented at "International Conference: Air Quality in Europe: Challenges for the 2000s" Venice 19-21 May 1999. Poster to be submitted as paper in a special number of Atmospheric Environment. (http://www.dmu.dk/atmosphericenvironment/docs/particles.htm)

WHO (2000): "Guidelines for Air Quality". (http://www.who.int/peh/air/Airqualitygd.htm)

WHO (1994): "Update and revision of the air quality guidelines for Europe, meeting of the working group "classical" air pollutants", Bilthoven, The Netherlands 11-14 October 1994, WHO Regional Office, Copenhagen 1995.

WHO (1996): "Particulate matter". World Health Organisation Air Quality Guidelines for Europe 1996. Final edited draft, September 1997.

Danish legislation

Environmental Protection Act, cf. Consolidated Act no. 698 of 22 September 1998 and subsequent amendments.

Act on Chemical Substances and Products, cf. Consolidation Act no. 21 of 16 January 1996 and subsequent amendments.

Statutory order no. 836 of 10 December 1986 on limit values for the content of SO₂ and particles in ambient air;

Statutory order no. 119 of 12 March 1987 on limit values for the content of NO₂ in ambient air.

Statutory order no. 184 of 11 March 1994 on monitoring and assessing the content of ozone in ambient air.

Statutory order no. 660 of 11 august 1997 on approval etc. of waste combustion plants.

Statutory order no. 41 of 14 January on waste combustion plants.

Statutory order no. 689 of 15 October 1998 on reduction of emissions of SO₂, NO_x and dust from large power plants.

Statutory order no. 792 of 15 December 1988 on reduction of emissions of asbestos to ambient air from industrial plants.

Statutory order no. 529 of 25 June 1999 on the quality of petrol and diesel oil for vehicles etc.

Statutory order no. 922 of 5 December 1997 on environmental requirements when establishing and running a garage, etc.

Statutory order no. 643 of 28 July 1997 on reduction of discharges of vapour when filling up the automobile tank with petrol.

Statutory order no. 667 of 14 September 1998 on reduction of air polluting emissions from mobile off-roaders.

Statutory order no. 852 of 11 November 1995 on reduction of discharges of vapour when storing and distributing petrol.

Statutory order no. 185 of 15 May 1981 on spraying with chemical substances from aeroplanes.

Statutory order no. 974 of 13 December 1995 on the use of ozone depleting substances.

Statutory order no. 807 of 25 October 1999 on activities to be approved by the environmental authority.

Guideline no. 6/1990 on Limitation of Industrial Air Pollution.

Guideline no. 9/1992, Industrial Air Pollution Control Guidelines.

Guideline no. 4/1985 on Industrial Odour Control.

Guideline no. 15/1996, B-værdier.

EU legislation

Directive 1999/13/EEC of 11 March 1999 on the limitation of emissions of volatile organic compounds due to the use of organic solvents in certain activities and installations.

Directive 96/92/EEC of 27 September 1996 on ambient air quality assessment and management (Air Quality Framework Directive)

Directive 99/30/EEC on limit values for sulphur dioxide, oxides of nitrogen, particulate matter and lead in ambient air. (the first daughter directive).

Directive 92/72/EEC of 21 September 1992 on pollution of ozone.

Directive 89/369/EEC of 8 June 1989 on prevention of air pollution from municipality waste combustion plants.

Directive 89/429/EEC of 21 June 1989 on reduction of air pollution from existing municipality waste combustion plants.

Directive 88/609/EEC on reduction of certain air polluting emissions from large power plants.

Directive 87/217/EEC of 19 March on prevention of pollution of asbestos.

Directive 98/70/EEC of 13 October on the quality of petrol and diesel oil, and

amendment of directive 93/12.

Directive 97/68/EEC of 16 December 1997.

Directive 94/63 of 20 December 1994 on prevention of emissions of VOCs when storing and distributing petrol from terminals and gas stations.

International accords

The 1985 Vienna Convention for the Protection of the Ozone Layer, including the 1987 Montreal Protocol on Substances that Deplete the Ozone Layer;

The 1979 Convention on Long-range Transboundary Air Pollution and its Protocols:

	the 1984 Protocol on the Long-term Financing of the Cooperative Programme for Monitoring and Evaluation of Long-range Transboundary Air Pollution
	the 1988 Protocol on the Control of Emissions of Nitrogen Oxides or their Transboundary Fluxes
	the 1991 Protocol on the Control of Emissions of Volatile Organic Compounds or their Transboundary Fluxes
	the 1994 Protocol on Further Reduction of Sulphur Emissions
	the 1998 Protocol on Heavy Metals
	the 1998 Protocol on Persistent Organic Pollutants
	the 1999 Protocol on Long-range Transboundary Air Pollution to Abate Acidification, Eutrofication and Ground-level Ozone.

The Vienna Declaration and the Programme of Joint Action adopted by the UN/ECE Regional Conference on Transport and the Environment at the Ministerial Level, 1997.

Charter on Transport, Environment and Health at the WHO Third Ministerial Conference on Environment and Health, 1999.

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