How Western Balkan Coal Plants Breach Air Pollution Laws and What Governments Must Do About It This Report Is Endorsed by the Following Organisations
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2020 UPDATE June 2020 COMPLY OR CLOSE How Western Balkan coal plants breach air pollution laws and what governments must do about it This report is endorsed by the following organisations: Research and writing Ioana Ciuta, CEE Bankwatch Network Pippa Gallop, CEE Bankwatch Network Davor Pehchevski, CEE Bankwatch Network Acknowledgements Viktor Berishaj, Climate Action Network Europe Nevena Petković, Green Home, Montenegro Mirko Popović, Renewables and Environmental Regulatory Institute, Serbia Denis Žiško, Center for Ecology and Energy, Bosnia and Herzegovina Editing Emily Gray, CEE Bankwatch Network Design Milan Trivić Cover photo Arben Llapashtica - Prishtina, Kosovo This publication has been produced with the financial assistance of the European Union. The content of this publication is the sole responsibility of CEE Bankwatch Network and can under no circumstances be regarded as reflecting the position of the European Union. Contents Glossary ...................................................................................................................................................................................5 Executive summary ..................................................................................................................................................................6 Introduction .............................................................................................................................................................................11 Regional overview of results ..............................................................................................................................12 Country profiles............................................................................................................................... ....................14 Bosnia and Herzegovina ................................................................................................................14 State of play with the NERP Compliance with the 2019 NERP ceilings Ongoing investments Kosovo ....................................................................................................................................................16 State of play with the NERP Compliance with the 2019 NERP ceilings Ongoing investments Montenegro .....................................................................................................................................20 Opt-out Emissions in 2019 Ongoing investments North Macedonia ..............................................................................................................................22 State of play with the NERP Compliance with the 2019 NERP ceilings Ongoing investments Serbia .......................................................................................................................................................25 State of play with the NERP Compliance with the 2019 NERP ceilings Ongoing investments Conclusions and recommendations ..............................................................................................................30 Glossary – Equipment for the reduction of nitrogen oxides emissions. De-NOX – Equipment for the reduction of sulphur oxide emissions. De-SOX EC – European Commission ELV – Emission limit value. This represents the permissible quantity of a substance contained in the waste gases from the combustion plant which may be discharged into the air during a given period; it is calculated in terms of mass per volume of the waste gases expressed in mg/Nm3. EnCom – Energy Community Energy Community Treaty – A Treaty signed in 2005 that entered force in 2006 and aims to extend the EU energy market to its nearest neighbours, by applying EU energy, environment and competition legislation to their energy sectors. The Treaty currently includes the European Union, Albania, Bosnia and Herzegovina, Georgia, Kosovo, Moldova, Montenegro, North Macedonia, Serbia and Ukraine. EU – European Union IED – Industrial Emissions Directive - Directive 2010/75/EU of the European Parliament and of the Council of 24 November 2010 on industrial emissions (integrated pollution prevention and control). LCP – Large combustion plant. This is defined as a technical apparatus which is used to oxidize fuel in order to use the heat generated with a rated thermal input of equal to or greater than 50 megawatts (MW). This includes plants such as fossil fuel or biomass-fired power stations and combustion in petroleum refineries. LCP BREF – Best Available Techniques Reference Document for Large Combustion Plants, the conclusions of which were made legally binding in Commission Implementing Decision (EU) 2017/1442 of 31 July 2017 establishing best available techniques (BAT) conclusions, under Directive 2010/75/EU of the European Parliament and of the Council, for large combustion plants (notified under document C(2017) 5225). LCPD – Large Combustion Plants Directive – Directive 2001/80/EC on the limitation of emissions of certain pollutants into the air from large combustion plants. MWe – Megawatts of electric power – the most common form of expression of a power plant’s capacity. MWth – Total rated thermal input of a power plant – the rating used in EU legislation to define different size categories of power plants. In general, it is harder to achieve lower emissions concentrations from smaller power plants, so pollution limits are differentiated by size. NERP – National Emissions Reduction Plan – a flexible implementation mechanism under the Large Combustion Plants Directive in the Energy Community whereby emissions can gradually be reduced by totalling their combined emissions and ensuring they are lower than the decreasing ceilings set for 2018, 2023, 2026 and 2027. – Nitrogen oxides NOX Opt-out – A flexible implementation mechanism under the Large Combustion Plants Directive whereby plants can delay investments in pollution control equipment as long as they limit their operating hours to 20,000 between 1 January 2018 and 31 December 2023. Any plants operating after that have to comply with the rules for emissions from new plants, not existing ones. PM or dust – Suspended particulate matter or dust particles. – Sulphur Dioxide SO2 1 Bosnia and Herzegovina, Kosovo*, Montenegro, North Macedonia and Serbia. Albania has no functional large combustion plants. *According to the Executive summary UN, Kosovo is “under the United Nations Interim Administration Mission in Kosovo (UNMIK) established pursuant to Security Council Resolution 1244.” In this publication it is referred to as “Kosovo”. 2 Montenegro is the nearest to In December 2019, Bankwatch published its Comply or Close report, which found that none of complying, as it is using a limited the Western Balkan countries with coal power plants1 had complied2 with the pollution limits for lifetime derogation called the “opt-out” 3 for its Pljevlja plant. This means the 2018 set under the Energy Community Treaty. plant can continue to operate until 2023 without pollution control investments as long as it does not operate for more Sulphur dioxide emissions from coal plants that were included in the National Emissions Reduction than a total of 20,000 hours. As long as Plans (NERPs)4 of Bosnia and Herzegovina, Kosovo, North Macedonia and Serbia5 totalled no fewer Montenegro closes or rehabilitates the plant within this period, it will not be in than six times as much as the 2018 ceilings set in the plans, while dust emissions amounted to breach of the Directive. 1.6 times as much as the ceilings. 3 The Energy Community Treaty entered into force in 2006 and is designed to extend the EU energy market to the This new report updates the findings with 2019 data reported to the European Environment EU’s southern and eastern neighbours. Agency,6 and regrettably finds no overall improvement. The Large Combustion Plants Directive (LCPD), was included in the Energy Community Treaty back in 2005 when In fact, between 2018 and 2019, sulphur dioxide (SO ) emissions from coal plants covered by the Treaty was originally signed. The 2 LCPD has already been superseded in NERPs actually increased from 603,988 to 617,281 tonnes rather than decreasing. This still the EU, where it was highly successful represents around six times as much as the combined SO ceilings for the four countries. in reducing air pollution from the 2 power sector. It is therefore only a first step to meeting current EU industrial emissions standards, but would still represent a strong step forward for the Western Balkans. 4 National Emission Reduction Plans are Figure 1 and Table 1: 2019 emissions ceilings breaches - Regional totals a mechanism which allows plants to be gradually brought into compliance as a group, with the better-performing plants balancing out the poorer-performing ones. National ceilings have been calculated for SO2, NOx and dust for Ceiling Emissions 2018, 2023, 2026 and 2027, and the sum of the plants’ emissions needs to be lower than this overall ceiling. By the 600000 end of the process, all the plants need to individually comply with the emission limit values for existing plants from the EU Industrial Emissions Directive. 500000 5 Montenegro could not have a NERP because it only has one large combustion plant. 400000 300000 SO2 ceiling 103,682.33 SO2 emissions 617,281.34 200000 Dust ceiling 11,199.32 Dust emissions 17,556.75 Emissions in tonnes 100000 NoX ceiling 97,225.94 NoX emissions 72,136.31 SO2 Dust NOX Substance 6 2020 Update - Comply or close Tuzla, Bosnia and Herzegovina