Climate Policy

Air quality: technical details for modelling applications and determining sampling points’ spatial representativeness

Kevin Doshi

This feedback is submitted by Kevin Doshi, Climate Department, Logos Research Centre, an independent policy research think tank. We welcome the direction this decision takes. Making air quality modelling a formal assessment tool is the right move, and the framework is broadly sound. That said, we've identified three areas where the draft falls short. The first concerns meteorological data. Under Article 2(d), it is treated as optional, despite its central role in determining how pollution moves and spreads. The second concerns data quality. Article 3(2) requires input data to be quality controlled "where possible", but never defines what that means, leaving a gap in accountability. The third concerns emissions data. Article 2(c) makes emissions requirements dependent on model design, creating a loophole that conflicts with the directive itself.