Diversity in sub-national EU implementation: the application of the EU Ambient Air Quality directive in 13 municipalities in the Netherlands

This paper offers an analysis of the implementation performance of the EU Ambient Air Quality directive in the Netherlands. It provides a systematic evaluation of the implementation of a procedural provision - the obligation to design air quality policy. It draws on original data on air quality policy measures that have been collected in 13 medium-sized Dutch municipalities. The analysis of differences in the implementation performance was performed using a novel three-dimensional conceptual framework. The findings illustrate great differences in the implementation performance between the municipalities. The focused comparison allowed establishing very precisely where the implementation performance is poor or even lacking, and which municipalities take their EU implementation task more seriously than others. Most puzzling, environmental problem pressure turned out not to act as a sufficient trigger for municipalities to take far-reaching air quality measures. In contrast to previous research, a more nuanced picture is painted when it comes to the concepts of 'compliance', 'non-compliance' and 'over-compliance'. A careful dissection of the implementation performance based on the aspects of the conceptual framework produces hands-on recommendations to municipalities seeking to improve their air quality policy.