Necessity of INSPIRE transformation for Air Quality e-Reporting data

[fab-fleischer]

Under the Commission Implementing Decision 2011/850/EU on reciprocal exchange of information and reporting on ambient air quality, Member States report air quality data to the EEA via the Air Quality e-Reporting data model.

The reporting guidelines and EEA documentation (e.g. Reporting and exchanging air quality information using e-Reporting, EEA 2012; Reporting of Air Quality Plans and Programs in Europe: Guidelines for INSPIRE-compliant data transmission, JRC/EEA 2014) state that this e-Reporting framework was designed to be INSPIRE-compliant “by design” and is aligned with INSPIRE Annex II/III themes, notably:
Environmental Monitoring Facilities (EF), Atmospheric Conditions (AC), Area Management, Restriction, Regulation Zones and Reporting Units (AM), Human Health and Safety (HH).

The INSPIRE Data Specification on Atmospheric Conditions and Meteorological Features (D2.8.III.13-14, v3.0, Section B.6) also explicitly recognises that reporting under 2011/850/EU must be compatible with INSPIRE.

My question is therefore:
For Member States that already report Air Quality data flows B, D, and E1b to the EEA in the required e-Reporting format:

• Are these datasets considered to already fulfil their INSPIRE obligationso or is an additional transformation into the formal INSPIRE application schemas (EF, AC, AM, HH) still legally required to be compliant with INSPIRE Implementing Rules (Regulation (EU) No 1089/2010)?

Actually, the documentation suggests that reporting and INSPIRE are harmonised but it would be helpful to have an official clarification.