Developing an effective Air Quality Plan: A practical guide for industry decision-makers

This article answers four core questions that Applus clients frequently raise, grounding each response in guidance from the European Union, the U.S. Environmental Protection Agency (EPA), the United Nations system, and other authoritative bodies.

What is an Air Quality Plan?

An air quality plan is a set of actions to be implemented (measures, implementation schedule, and investments) to ensure the protection and improvement of air quality, human health, and the environment in general. In corporate settings, the document typically covers:

• Baseline assessment of ambient conditions through air quality monitoring and dispersion modelling.
• A quantified emission inventory that links on-site activities to pollutant loads (EMEP/EEA, 2023).
• Clearly defined targets, linked where possible to the Air Quality Index (AQI) so non-specialists can interpret progress.
• A suite of mitigation measures—engineering controls, process optimisation, low-carbon fuels, or offsets—framed within a cost-benefit context (World Bank, 2023).
• A compliance and reporting schedule aligned with statutory frameworks such as U.S. State Implementation Plans (US EPA, 2025) or EU National Air Pollution Control Programs.

Viewed against the Air Quality Management Cycle—problem definition, data gathering, control strategy design, implementation, evaluation, and review (US EPA, 2024)—the AQP serves as both a roadmap and a scorecard. It converts that iterative cycle into a binding, auditable commitment.

Why AQP (Air Quality Plan) matters for industry

Beyond meeting regulatory requirements, a robust AQP can unlock operational savings via energy efficiency, improve community relations, and contribute to ESG ratings—all critical differentiators when attracting capital and talent. Applus supports clients by combining Air Quality Testing in accredited laboratories with advanced atmospheric dispersion modeling tools, giving decision-makers high-confidence data on which to build their plans.

 

In what situations should an Air Quality Plan be prepared?

Legislation worldwide mandates an AQP whenever pollutant levels exceed limit or target values in a given airshed, but a growing number of companies are acting before exceedances occur. Situations that typically trigger plan development include:

1. Compliance with regulatory requirements. In the case of Directive (EU) 2024/2881, Article 19 specifies in which cases Member States must draw up air quality plans. U.S. facilities located in non-attainment areas face similar obligations through SIPs.
2. Major capital projects or environmental permit renewals. New industrial plants, expansions and infrastructure upgrades often undergo environmental impact assessments that recommend an AQP to mitigate projected emissions (UNECE, 2015).
3. Corporate sustainability targets. Companies committing to net-zero or science-based targets utilize AQPs to integrate greenhouse gas emissions reductions with local air pollution controls (IMF, 2022).
4. ESG-driven stakeholder pressure. Investors and communities are increasingly expecting transparency in emission quantification and control strategies (World Bank, 2023).
5. Voluntary certification schemes. Standards such as ISO 14001 encourage the development of structured air-quality action plans as part of broader environmental management systems.

 

Which regulations require an Air Quality Plan?

European Union. Directive (EU) 2024/2881 establishes when Member States must draw up air quality plans, air quality roadmaps, and even short-term action plans in areas where the limit or target value established for a pollutant is exceeded. Sector-specific directives—for example, the Industrial Emissions Directive—link permitting to demonstrable improvements in air quality.

United States. Under the Clean Air Act, areas failing to meet National Ambient Air Quality Standards (NAAQS) must develop SIPs describing how they will attain compliance; individual facilities may be assigned source-specific measures within those plans (US EPA, 2025).

International Conventions. The 1979 Convention on Long-range Transboundary Air Pollution (LRTAP) and its protocols require signatories to prepare action plans addressing pollutants with cross-border effects (UNECE, 2015).

Guidance Bodies. While not legally binding, the World Health Organization (WHO) air-quality guidelines (2021) serve as de facto benchmarks in many jurisdictions and influence local plan requirements. The International Panel on Climate Change (IPCC) offers methodologies for integrating greenhouse gas emissions accounting into AQPs (IPCC, 2019).

Companies operating across multiple territories must therefore map their activities against a mosaic of regional and international rules. Relying on an environmental consultancy firm with a global presence enables harmonised compliance strategies, reducing the administrative burden for multinational clients.

 

What parameters should be measured in an Air Quality Plan?

An effective AQP aligns measurement parameters with both health-based standards and source-specific emission profiles. Core categories include:

 

Parameter category	Typical metrics	Key references
Criteria pollutants	SO2, NO2, NOx, PM10, PM2,5, benzene, CO, As, Pb, Ni, benzo(a)pyrene, O3	Directive (EU) 2024/2881
Hazardous air pollutants	Benzene, formaldehyde, metals	LRTAP protocols; national toxics lists
Greenhouse gases	CO₂, CH₄, N₂O (scope 1); process-specific gases like HFCs	IPCC, 2019
Meteorological data	Wind speed & direction, temperature, humidity	US EPA, 2024
Process and activity data	Fuel use, production throughput, and abatement efficiency	EMEP/EEA, 2023

 

 

 

 

 

 

 

 

 

 

 

Measurement and monitoring tools. Advances in sensor technology have expanded options from fixed reference stations to mobile platforms and low-cost air quality monitors. When paired with air pollution control equipment data and modelling, these devices allow real-time optimization of mitigation measures.

Data integration and quality assurance. International guidelines emphasize uncertainty analysis, representativeness and data validation. It is highly recommended to complement on-site sampling with laboratory analysis accredited to ISO/IEC 17025, ensuring defensible datasets for regulatory reporting.

Implementing, monitoring and updating the Plan

Regulators increasingly expect continuous improvement. Both the EU and EPA require periodic review of mitigation efficacy and, where necessary, plan revision. A robust implementation framework therefore, includes:

• KPIs tied to the AQI for easy communication to internal and external stakeholders.
• Digital dashboards that aggregate emissions, air pollution monitoring data and performance of control devices.
• Third-party verification to validate progress and secure stakeholder trust.

 

By structuring the AQP as a living document aligned with the Air Quality Management Cycle, organisations can respond quickly to new evidence, emerging technologies or evolving regulatory thresholds.

 

Conclusion

Rising regulatory ambition, investor scrutiny and community expectations make an Air Quality Plan more than a compliance checkbox; it is a strategic tool to safeguard business continuity and brand value.

Successful plans [1] clearly define objectives within recognised legal frameworks; [2] quantify baseline conditions through comprehensive air quality testing and modelling; [3] prioritise mitigation actions that deliver co-benefits for climate, health and operations; and [4] establish robust monitoring and reporting protocols, leveraging modern air pollution monitoring technologies.

As a strategic partner, Applus+ offers a fully integrated suite of air-quality services that covers the entire management cycle, including baseline assessments and monitoring campaigns, accredited gas-emissions testing and emission inventory preparation, Air Quality Control audits, dispersion modeling and plan drafting, continuous air-pollution monitoring, and independent third-party verification. This turnkey approach combines global best practices with local regulatory expertise, enabling organisations to efficiently meet compliance requirements while leveraging regulatory pressure into a competitive edge that delivers cleaner air and measurable sustainability gains.