Appendix 1: Draft Environmental Permitting (England and Wales) (Amendment) Regulations 2018
Additional Information from the Department for Environment, Food and Rural Affairs
“Q1: At present, what proportion of the relevant measurement of air pollution is accounted for by emissions from existing Medium Combustion Plants? What reduction in this air pollution is expected from the application of new controls to existing Medium Combustion Plants in 2024 and 2029?
A1: The projections in the impact assessment are based on an estimated numbers of plants in 2011 which are based on market intelligence and have been adjusted for a number of factors that determine fuel consumption. These estimates indicate that medium combustion plants (MCPs) emitted 32.67 kilo tonnes (Kt) SO2, 41.5 Kt NOx and 6.2 Kt of particulate matter in 2011. As a comparison, total emissions in 2011 were 393 Kt SO2, 1,061 Kt NOx and 318 Kt particulate matter.
Table 1.1 below is taken from the MCPD impact assessment. It provides a summary of the emissions reductions expected to be delivered by the emission controls on MCPs by 2030.
Table 1.1 Emission reductions delivered in 2030 by proposals assessed in the impact assessment, in kilo tonnes (Kt) and as a percentage of total UK emissions.
Kt (%) |
SO2 |
NOX |
PM |
CO2 |
|
Option 1 |
14.5 (12%) |
16.9 (3%) |
2.6 (3%) |
109 |
Q2: Can you spell out what are the controls which the Regulations introduce for electricity generators? When will they be applied? What proportion of emissions of nitrogen oxides is accounted for by such small-scale generators? What difference will the new controls make, and when?
A2: Within Great Britain, there has been rapid growth in the use of low-cost, small scale flexible power generators in the past few years. Whilst there is a legitimate role for some rapidly-responding small-scale generation, there has been a recent growth of (mainly diesel) generators which emit high levels of NOx relative to other MCPs and are not subject to emission controls. This growth poses a concern for local air quality as well as for meeting future national emission reduction targets. These generators have the potential to cause breaches of the hourly NO2 limit set for the protection of human health within the EU Ambient Air Quality Directive (EU AAQD). If the growth in their use remains unconstrained, this will result in an avoidable increase in national emissions, posing a risk to meeting the ceilings established within the Gothenburg Protocol. Therefore the Government is taking action to ensure the UK population’s exposure to NO2 is within the maximum levels permitted under EU law.
The MCPD requirements are not sufficient to tackle emissions from the increased use of these generators. Our proposed generator emission controls mean that new generators will be subject to permitting and a NOx emission limit from 1 January 2019. The regulator is also able to set stricter emission limits if required to ensure compliance with an environmental quality standard, i.e., to protect local air quality. Existing generators will not need to meet the emission limit until a later date. This date depends on their size, their emissions, and whether they have an existing agreement with National Grid. These transitional agreements will be removed if the operator signs up to a new agreement with National Grid after 31 October 2017 (which remains in place after 31 December 2018). This is to avoid favouring and encouraging the use of older, more polluting generators, whilst also providing time for the market to adapt. Additionally, existing generators that are very highly polluting (emits 500mg/Nm3 of NOx or more, operates for 50hrs or more per year, and which is 5MWth or larger) may have emission limits set from October 2019 if required to protect local air quality.
Table 1.2 below is taken from the generator controls impact assessment. It provides a summary of the emissions reductions expected to be delivered by the emissions controls on generators by 2030.
Table 1.2 Emission reductions delivered in 2030 by the controls on high NOx generators, in kilo tonnes (Kt) and as a percentage of total UK emissions.
Kt (%) |
SO2 |
NOX |
PM |
CO2 |
|
Option 1 |
0.3 (0.2%) |
2.1 (0.5%) |
0.02 (0.04%) |
12 |
The analysis for the high NOx generators uses a baseline scenario in which there is implementation of the MCPD but no emission controls on generators. It is relative to this baseline that the impacts of implementing emission controls on high NOx emitting generators are assessed.
Q3: How do you explain the divergence between respondents’ views on the issue of particulate emissions, and the Government’s own view? Are the Government not concerned about the point made, in relation to ensuring confidence in the regime and establish robust data on particulate emissions?
A3: Particulate matter emissions are a potential concern only for older, unabated or poorly maintained generators. As a result it was not proportionate to set emission limits for all generators and require periodic monitoring to demonstrate compliance. Instead we have provisions which enable the regulator to set additional emission controls if required to protect local air quality. We also have maintained the prohibition on persistent emissions of black smoke as set out in the Clean Air Act. It’s also important to note that black smoke from diesel engines will occur only briefly at start up or shut down, or if something is badly wrong with the generator.”
21 December 2017