ACQJ editorial office
Three independent documents, a citizen monitoring, an analysis of official air quality data and a state audit, lead to the same conclusion: citizens' exposure to pollution is high and continuous, while the institution that should prevent it, the National Environment Agency, is not exercising the basic functions for which it exists. The consequence is not only environmental, but also institutional: legal standards exist, but their implementation remains, as the state audit itself describes, mainly formal.
In December last year, at the SM2 monitoring station on Kavaja Street in Tirana, the concentration of PM2.5 particles reached 75 micrograms per cubic meter, fifteen times above the World Health Organization guideline limit of 5 μg/m3. In the same month, PM10 reached 86.5 μg/m3. This was not the only case: in the months of August–November of the same year, the same station recorded values between 7 and 11 μg/m3.
The same applies to noise, which in public discourse is often treated as a secondary problem compared to air, but which the alternative monitoring report documents as equally structural. Of the 300 monitored points in Tirana, 78 percent exceed the guideline standard of 55 decibels during the day, and about half of the city does not reach the minimum level of quiet at night, with some stations, such as TR272, at 71 decibels, remaining practically uninhabitable for a healthy sleep according to international medical criteria.
A national trend, not just Tirana
Official data from the National Environment Agency, analyzed in the report conducted by Qëndresa Kyyetare , confirm that this is not just a local story about a Tirana street. The national average of PM2.5 has almost doubled between 2019 and 2024, from around 10 to over 16 μg/m3, while nitrogen dioxide (NO2), the indicator most closely linked to urban traffic, has increased from 19.11 to 25.45 μg/m3 in the same period. PM10 peaked at μg/m3 in 2023, before falling slightly in 2024. These figures remain formally below the annual limits of the European Union, but move in the opposite direction to what would be expected from a country that declares continuous approximation to European environmental standards.
Elbasan is the clearest case where this trend goes from worrying to illegal: in 2024, PM2.5 in the city reached 30.15 μg/m3, above the EU annual legal limit of 25 μg/m3. The rest of the indicators, NO2, sulfur dioxide, ozone, benzene, remained within the standards, which isolates fine particles as the main source of local risk and opens the question of which specific activities are causing it. Korça and Durrës, meanwhile, show a continuous increase in tropospheric ozone since 2023, another form of pollution, linked to summer photochemical reactions, which risks going unnoticed if public attention remains focused only on winter particles.
The system that measures little and measures poorly
What links the two monitoring reports is a common weakness: Albania does not accurately recognize the extent of the problem it describes. The official network of the National Environmental Agency has only seven automatic measuring stations throughout the territory, some of which, according to the European Commission’s ongoing reports on Chapter 27 of the accession negotiations, do not function regularly due to a lack of funds for maintenance. The official data themselves betray this gap: some cities and years report values of 0 μg/m3 for some pollutants, a figure that in practice indicates not clean air, but out-of-function instruments.
This lack of coverage creates a gap that civil society organizations are trying to fill. The GreenAL and Co-PLAN alternative monitoring network has expanded from 13 initial points on the Small Ring Road of Tirana to over 800 air and noise points and 40 water points in six major municipalities by 2025. Milieukontakt, in an independent comparison in Durrës for 2023, recorded an average PM2.5 of 25.28 μg/m3, more than double the official average of 12.24 μg/m3 for the same city and period.
The air quality report carefully qualifies this difference: alternative monitoring “does not necessarily contradict official data, but complements them by identifying hotspots,” a diplomatic phrasing for the simple reality that the state measurement network is not capturing the heaviest part of citizen exposure.
Up to this point, the story could be read as a technical failure: few stations, insufficient budget, fragmented monitoring. The full compliance audit that the Supreme State Audit has conducted on the activity of the National Environmental Agency shows something deeper, that the institution itself responsible for permits, impact assessments and environmental inspections is not exercising this role even in the part that does not require additional funds, but simply compliance with procedures.
The SAI documents specific cases where type A and B environmental permits were approved without a prior environmental impact assessment (EIA), even though the law requires this step for high-risk projects: an electrical equipment manufacturer, a mine in Bulqiza, a brewery, a limestone quarry. In other cases, permits were granted without waste disposal contracts, fire protection reports, or public consultation documentation required by law, as happened with a subject where the minutes claimed that a public hearing had been held, while the relevant form was completely missing from the file. In another case, a type B permit entered into force through a “silent approval” mechanism, without any act signed by the ministry, a practice that the audit itself considers to be in direct violation of law no. 10448.
The financial dimension of this failure is as significant as the regulatory one. Due to a lack of coordination between the licensing, monitoring and finance departments within the agency itself, the annual fees that licensed entities must pay have not been planned as budget revenues for 2020 and 2021, creating a difference of 13.04 million lek. In parallel, 840 entities have unpaid liabilities of 8.52 million lek, accumulated from 2015 to June 2020, without any identified list of debtors.
The database on active permits contains 1,274 permits in the old format and 590 environmental assessments or statements, many of which remain formally in force even when the entity has been suspended at the National Business Center, or even when a new permit has subsequently been issued for the same installation, without the old one being officially revoked.
Equally concerning is the enforcement of sanctions. When the Agency's inspectors imposed fines of up to 1 million lek for verified violations, wastewater discharges, and failure to deliver waste, the appeals committee overturned some of them, acknowledging in the decision that the violations existed, but without providing a strong legal justification for the annulment of the measure.
There is still no public list of the 840 debtors to the National Environment Agency, nor an independent health assessment that directly links hospital bed data to the pollution map. The Ministry of Tourism and Environment had not responded, at the time of the audit, to the Agency’s own request for a common database of debtors.
Meanwhile, the annual and monthly inspection plans result in partial and without any risk analysis in the selection of entities to be inspected, which means that the system is not oriented towards those that cause the greatest damage, but functions mainly in a routine manner.
European law, partial implementation
Albania has transposed most of the European legal framework for air and water quality: Directive 2008/50/EU, Law No. 10431/2011 “On the Protection of the Environment”, Law No. 162/2014 “On the Protection of Air Quality”, the National Air Quality Strategy of 2014 and the National Air Quality Management Plan of 2019. For recreational and drinking waters, VKM No. 797/2010 and VKM No. 379/2016 apply, comparable to the standards of the World Health Organization and FAO.
The problem, as one of the reports itself formulates, is not the lack of legislation, but the fact that “approaches to legislation… must be applicable in practice, so as not to lose the purpose for which they were created… and not remain simply printed on paper.”
The European Commission's annual reports on Chapter 27 have been repeating this observation consistently for years: insufficient monitoring network, data not in real time, strategies not yet fully implemented.
The consequences of this combination, high exposure plus poor surveillance, fall on citizens. Residents of neighborhoods along high-traffic corridors in Tirana live with noise levels above 60 decibels during the day and often above 45 at night, levels that are medically linked to sleep disorders and higher long-term cardiovascular risk. Children and the elderly, who are more sensitive to fine particles, are the most exposed group during winter episodes like the one on Kavaja Street.
In communities near mines or plants that have received permits without a full impact assessment, the environmental risk remains officially undocumented, and therefore invisible in national statistics. Businesses that follow full procedures, meanwhile, compete on an unequal playing field with those that receive permits with incomplete documentation or escape fines through appeal.
What the three reports jointly put on the table is a single, straightforward question: how much sense does it make to demand stricter implementation of environmental standards from citizens and businesses, when the legal institution responsible for administering these standards, from the first permits to the last fines, has not yet managed to establish order on its own database and on the collection of obligations that the law itself grants.
There is still no answer as to how the National Environmental Agency, the Ministry of Tourism and Environment, and the main municipalities will now act on these findings, whether the recommendations of the High State Audit will be followed, whether the decisions of the appeals committee will be reviewed, and whether the measurement network will be expanded beyond the seven existing stations./ acqj.al
