Analysis of the Impacts of Various Options to Control Emissions from the Combustion of Fuels in Installations with a Total Rated Thermal Input Below 50 MW
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European Commission Analysis of the Impacts of Various Options to Control Emissions from the Combustion of Fuels in Installations with a Total Rated Thermal Input below 50 MW Revised Final Report February 2014 AMEC Environment & Infrastructure UK Limited Copyright and Non-Disclosure Notice The contents and layout of this report are subject to copyright owned by AMEC (©AMEC Environment & Infrastructure UK Limited 2014). save to the extent that copyright has been legally assigned by us to another party or is used by AMEC under licence. To the extent that we own the copyright in this report, it may not be copied or used without our prior written agreement for any purpose other than the purpose indicated in this report. The methodology (if any) contained in this report is provided to you in confidence and must not be disclosed or copied to third parties without the prior written agreement of AMEC. 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Document Revisions No. Details Date 1 Draft final report outline for client 2 November 2012 comment 2 Draft final report 17 April 2013 3 Final report 15 May 2013 4 Revised final report including 10 September 2013 additional modelling results 5 Revised final report taking into 17 January 2014 account client comments 6 Revised final report 12 February 2014 © AMEC Environment & Infrastructure UK Limited February 2014 S:\Projects\33006 PPAQ EC Small Combustion Plants IA\C Client\Reports\Revised Final Report 2\33006 Revised Final Report_(2)_20140212.docx © AMEC Environment & Infrastructure UK Limited February 2014 S:\Projects\33006 PPAQ EC Small Combustion Plants IA\C Client\Reports\Revised Final Report 2\33006 Revised Final Report_(2)_20140212.docx i Executive Summary Introduction AMEC Environment and Infrastructure UK Limited (‘AMEC’) were contracted by the Commission to undertake the following study: “Analysis of the impacts of various options to control emissions from the combustion of fuels in installations with a total rated thermal input below 50 MW”. A lot of work has already been undertaken looking at installations less than 50 MWth. Therefore this study aimed to build on the data gathered previously by supplementing it with new information focussed on the key gaps identified in previous studies. This final report provides a summary of the additional data that was gathered from the Member States and industry and the main findings of the analysis. This includes the development and final composition of the EU27 database of combustion installations less than 50 MWth, the options considered and associated compliance and administrative costs and emission reductions. This report also includes the results of some additional modelling undertaken by AMEC to support the Commission’s development of a draft Impact Assessment of proposals to control emissions from these installations. Data gathering and compilation A dataset of numbers, capacities and emissions estimates for combustion plants between 1 and 50 MWth was developed under a previous study (AMEC, 2012). Adjustments and additions were made during its development to ensure the dataset was representative for the EU to support an assessment of the total EU potential costs and benefits for controlling emissions from these plants. Gaps that were identified were filled, and partial information submitted were adjusted and / or supplemented when necessary. The previous study’s dataset was used as a starting point for this study. The aim was to improve the data, which included consultations with stakeholders and requesting updates and feedback from Member States on the gap filling techniques and the assumptions applied. Section 2 of this report describes our approach for data gathering including the stakeholder consultation and a summary of the data received. Although more complete than the dataset compiled for AMEC (2012), some gaps still remained. In particular, no data was provided for Bulgaria, Greece, Lithuania, Luxembourg and Portugal. Italy, Ireland and Slovenia indicated they were not in a position to submit any new information. Spain and the United Kingdom each provided information for only one region and Romania only commented on the terms of reference of this project issued by the Commission. Section 3 of this report describes how the updated dataset has been developed, including the gap filling that has been undertaken. The table below provides an overview of the resulting EU27 dataset with all of the amendments, additions, updates and assumptions as described in the report. © AMEC Environment & Infrastructure UK Limited February 2014 S:\Projects\33006 PPAQ EC Small Combustion Plants IA\C Client\Reports\Revised Final Report 2\33006 Revised Final Report_(2)_20140212.docx ii Table 1 Summary of EU27 Dataset Datum 1-5 MWth 5-20 MWth 20-50 MWth Number of plants 113,809 23,868 5,309 Capacity of plants (GWth) 273,714 232,367 177,099 Fuel consumption: Biomass (PJ) 163 160 182 Other solid fuel (PJ) 49 46 74 Liquid fuel (PJ) 213 290 206 Natural gas (PJ) 1,268 1,704 844 Other gaseous fuel (PJ) 277 125 104 Total fuel consumption (PJ) 1,971 2,325 1,410 SO2 emissions (kt) 103 130 68 NOx emissions (kt) 210 227 117 Dust emissions (kt) 17 20 16 Options for the control of emissions from combustion installations less than 50MWth The table below provides a high level summary of the main regulatory options considered in this study. Table 2 Overview of Regulatory Options Regulatory Option Summary This could operate in two main ways: i. Integrated permit regulating installations similarly as IED installations under Chapter II and Annex A. “Permitting”: I (permit, BAT). ii. Light permit similar as above but without public participation. Regulating air emissions from installations via EU wide ELVs, but without a full permitting regime and without BAT obligations. As for the permitting option, this could operate in two ways: B. “Non-permitting”: i. All plants must provide a notification to the Competent Authority who will maintain a database of plants. ii. No notification to the Competent Authority. The main difference between the two options from the table above, namely the “permitting” (regulatory option A) and “non-permitting” (regulatory option B) options is in relation to the administrative approach and the way in which combustion installations would be regulated i.e. permitting versus non-permitting regimes. © AMEC Environment & Infrastructure UK Limited February 2014 S:\Projects\33006 PPAQ EC Small Combustion Plants IA\C Client\Reports\Revised Final Report 2\33006 Revised Final Report_(2)_20140212.docx iii For each of these options we have applied a range of differing levels of ELVs to evaluate environmental and economic impacts. The Primary NOx, IED 50-100 MW and Most Stringent MS scenarios have been assessed on the basis that the ELVs would apply to all plants within scope in a given year, without differentiating between the ages, operating profile or sector of the plant or the timescales for when limits have to be met. For the Gothenburg and SULES scenarios, differentiation is made between new and existing plants with new plants being required to meet more stringent ELVs than existing plants. The timescale for implementation for these two options is also different, with compliance modelled for new plant from 2018 and existing plant from 2022. This will allow a longer time period for existing plant to retrofit abatement measures within normal investment cycles, and potentially encourage early replacement of aging plant. Furthermore, these two scenarios incorporate an exemption for plant operating less than 300 hours per year. A proportion of plant of the 1-50 MW size range are stand-by or back up plant and are therefore likely to operate for a small number of hours per year. For such plant, the installation cost of abatement technology is disproportional to the total annual emissions reduced due to the low utilisation. The ELVs applied in the modelling are summarised in the table below (further details of the individual ELVs applied for the baseline and different scenarios are provided in Section 4 for the Most Stringent MS, IED 50- 100MW and Primary NOx options and in Section 9 for the Gothenburg and SULES options). Table 3 Overview of ELV Options ELV Option Summary The ELVs for this option have been set to be equal to the most stringent ELVs in MS national legislation for each fuel Most Stringent MS and technology type and plant capacity. IED 50-100MW The ELVs for this option have been set to be equal to those for existing 50-100 MWth combustion plants in the IED. A less stringent set of limits for NOX which have been set at a level to only require the uptake (if at all) of primary Primary NOx abatement measures have been modelled, for both regulatory options, as a further sensitivity. The ELVs for SO2 and dust are the same as under the IED 50-100 MW scenario.