A Recipe for Zero-Pollution Climate Policies: Win-win Solutions for Cleaning the Air and Protecting the Climate 

By Niklas Löther, Project Researcher 

Photo by Benjamin on Unsplash.  

Around 400,000 premature deaths each year are attributable to air pollution in Europe. Yet, the subject is increasingly sidelined by the climate crisis in public debate – despite the European Green Deal setting both carbon-neutrality and zero-pollution as goals for 2050. Indeed, we should not be thinking of these goals as competing in the first place: Warming and air pollution share many sources and several pollutants are themselves heating agents, so win-win solutions do exist. There are also trade-offs between them, however, that must be considered.  

While climate-pollution interactions are popular topics for scientific research and in international fora like the World Health Organisation or the Climate and Clean Air Coalition – the latter of which is entirely dedicated to the subject – they garnered less attention in the research and practice of EU law. However, CCEEL has continuously worked on the subject from a legal and policy perspective for a whole decade now. As part of this research (currently continuing under the ClimAirPathways project) and based on scientific literature on the subject, we can formulate a first draft for a practice-oriented recipe for zero-pollution climate policies. Here are five steps these should follow: 

1. Always remember: Climate-neutral ≠ Zero Pollution 

The most important first step to integrated policies is realising that not all climate action improves air quality. As the climate crisis rose on the agenda, the framing around “sustainability” has increasingly narrowed to a point where the term is now often used interchangeably with climate action, obscuring trade-offs between decarbonisation and other environmental priorities. Yet, such trade-offs exist – including with clean air: Most notoriously, the EU spent many years promoting the adoption of diesel cars because their carbon emissions are lower than petrol cars’ – until it emerged that they also produce significantly more particulate pollution. To this day, one fifth of EU citizens breathe air failing to meet quality standards set in the Ambient Air Quality Directive – relatively unambitious values compared to WHO recommendations – and diesel cars are a key reason for this.  

Likewise, not all pollution control also mitigates warming: For instance, stricter standards for sulphur emissions from ships contributed to recent spikes in ocean temperatures, as the absence of this pollutant reduced cloud formation over shipping routes. Besides, a decline in atmospheric sulphur concentrations may even increase greenhouse gas emissions from wetlands, further complicating the picture. Hence, while we may intuitively think combatting climate change always goes along with reducing pollution, reality is more difficult. To design synergistic policies or at least minimise the above trade-offs, such complexities should not be ignored, meaning the discourse around sustainability must broaden to consider environmental threats beyond the climate crisis as well. 

2. Technology is not neutral: Avoid combustion wherever possible 

As the sustainability agenda has narrowed around climate action, it also increasingly focuses on technological solutions: Biofuels and electric vehicles (EVs) have been developed to replace fossil fuels in transport, renewable energy, like wind, solar and biogas, do the same for our energy mix, and there are plans to capture and store any remaining carbon after its emission. “The more the merrier” has been the general approach to these technologies, with significant subsidies allocated to all the above, rather than picking winners. Technological neutrality is becoming a buzzword in Brussels and member state capitals, meaning that all low-carbon technologies should be supported and the market, not politicians, should choose which wins.  

This, however, is only true for carbon emissions and, again, ignores air pollution: For example, biofuels may not emit fossil carbon when burned but their chemical composition is not that different from fossil fuels, so the pollution impact is effectively the same. Similarly, carbon capture selectively removes one component of atmospheric emissions, CO₂, but leaves any other pollutants there for us to breathe. From a health perspective, a better attitude to technology than “the more the merrier” would be “no smoke without fire”, i.e. avoiding combustion wherever possible, as combustion processes produce most particle pollution. Essentially, if it looks like pollution and it smells like pollution, then it is pollution – even if it does qualify as low-carbon.  

Of course, combustion cannot always be avoided and there is a place for bioenergy, too. However, it would be a waste to use these limited resources in sectors like road transport, where viable non-combustion alternatives such as EVs exist. Instead, they should be reserved for hard-to-abate sectors like aviation and shipping, where electrification is implausible. Also, not all combustion is equally bad: Generally, the more solid the fuel, the dirtier its emissions – so biogas is more worthy of support than biodiesel or, worst of all, solid biomass. Nevertheless, the EU’s Renewable Energy Directive sets a sector-wide target for biofuels in transport, rather than specific goals for aviation or shipping, and even condones the use of “sustainable” solid biomass. Member states thus support all sorts of bioenergy across various sectors, often even including wood in residential heating – the biggest single cause of particle pollution in most EU cities. In such cases, technological neutrality amounts to health indifference. It would be healthier to abandon this principle and support only the most viable low-carbon technologies that also minimise pollution. 

3. Time – and place – is of the essence: Lives are at stake 

The focus on technologies, including some not yet viable at scale like carbon capture or green hydrogen, implicitly shifts time horizons for emissions reduction backwards: As technology will save us in the end, immediate changes become less important. Another example of this is revived focus on nuclear energy, e.g. in Italy or Germany: While theoretically climate-neutral and zero-pollution, (re-)developing a nuclear sector from scratch where this technology is not currently in use would take decades. From a climate perspective, this can be justifiable if long-term emissions goals are met – but the same logic does not apply to air pollution: Compared to the more gradual and cumulative nature of climate change, pollution is an acute health crisis caused overwhelmingly by current emissions and must be tackled immediately. Postponing action even just a few years – let alone decades, the timeframe of many climate policies – risks millions of lives. 

Besides long-time horizons, the technological and market-driven approach predominant in current environmental policies also fails to tackle pollution at the right spatial scale: Treating emissions reduction as a market implies that the location of the reduction does not matter, but only its cost. This again applies only to the cumulative problem of climate change – not the more immediate air pollution threat: Pollutants have shorter atmospheric lifetimes than CO₂, so most stay near the area of emission rather than diffuse globally, creating regional hotspots for instance in cities, but also in energy-poor rural regions, where cheap biomass or coal are main sources of heat. Integrated climate and pollution strategies should therefore prioritise immediate emissions cuts and do so particularly where health benefits will be greatest. For example, this means targeting traffic and heating emissions, which are highest in population centres, including by alleviating energy poverty. Focusing on nuclear energy or carbon capture distracts from these urgent issues. 

4. Technology won’t save us: Behavioural change is needed 

Steps 1-3 have been fixated on technological change, as have policymakers, but this alone is not the solution. For example, while electrifying transport significantly cuts fine particulate pollution, it simultaneously increases emissions of larger particles from tyre and brake abrasion, as EVs are much heavier than petrol cars. EVs may reduce air pollution overall but their health impact is not zero – so transport strategies should promote not just alternative vehicles but also alternatives to driving altogether. Furthermore, we have not yet discussed another major source of air pollution, agricultural livestock: Its emissions can be decreased by optimising feeding techniques and manure management – but only to an extent, meaning impactful climate and pollution policies should target dietary preferences, too. There is no such thing as production without environmental externalities, so part of the transition to sustainability will have to come through changes in our behaviour and consumption. 

5. Never stop learning 

Finally, one caveat: While the above steps are all backed by ample evidence, there are still many unanswered questions on climate-pollution interactions. Furthermore, there are doubtlessly also questions we aren’t yet asking but should be. For example, the above-mentioned warming impacts of policies tackling shipping pollution surprised decisionmakers at the time – so we must anticipate unexpected results. While climate change is remarkably well understood overall, science on its interactions with air pollution – particularly in the form of aerosols – keeps evolving and involves significant uncertainties. Integrated climate-pollution policymaking must therefore be responsive to new scientific insights and entail constant learning from past experience. After all, both climate change and air pollution are wicked problems in their own right, rendered more complex still by the many interactions between them. 

There is a push to make environmental laws more adaptive and to strengthen science-policy dialogues. This is particularly notable in the European Climate Law, which requires all EU legislative proposals to be assessed for compatibility with climate neutrality and established a scientific advisory board to inform the Commission’s climate policies going forwards. However, no equivalent statutory advisory body or legislative compatibility check exists for the Green Deal’s other objectives, including the zero-pollution goal, so there is much room for improvement. A willingness to keep learning about complex climate-pollution interactions – rather than just narrow scientific advice on climate or pollution effects – would be another crucial ingredient for more integrated policies and laws. 

While the final step in the above list is to never stop learning, it may be more appropriate to demand that we start learning in the first place. The European Commission’s new “Clean Industrial Deal”, which guides EU environmental policymaking going forwards, places great emphasis on “the principle of technological neutrality”. There is a not-so-subtle political campaign to mobilise this principle against the 2035 phaseout of the internal combustion engine. Furthermore, the Commission is hinting that its technology-neutral approach will open the door to more funding for carbon capture and potentially even nuclear energy. Evidently, human health is not adequately considered here.  

Indeed, despite its name suggesting otherwise, the Clean Industrial Deal includes no mention of air pollution or indeed pollution of any kind. Its only environmental objective is climate-neutrality – a much narrower scope than the Green Deal, which also called for zero pollution and nature restoration, among others. Also, unlike the Green Deal, the Clean Industrial Deal counts exclusively on technological change, without any reference to necessary behavioural shifts. The first legislative proposal following this, the omnibus I package, essentially dismantles corporate sustainability due diligence and reporting obligations, particularly on pollution prevention and control. The Green Deal’s objectives can consequently no longer be taken for granted.  

Whatever the Commission is cooking up with the Clean Industrial Deal (the details are still emerging), it is not following the above recipe. Moving towards technological neutrality and away from the more holistic agenda of the Green Deal is not a recipe for integrated policies. From a human health and air quality perspective, it is a recipe for disaster.