8/12/2019 Notat fra EHP om LCP BREF

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STATEMENT EUROHEAT & POWER ON DRAFT LCP BREFJanuary2014

The current process establishing Large Combustion Plant Best available technology REFerence Document(LCP BREF) is more than technical work. Its conclusions will have far-reaching implications for the whole

energy sector across Europe and will set the conditions for the delivery of permits for installations above 50

MW.

On the heat market, the increasing costs to implement emission limit values (ELV) foreseen in the firstdraft have the potential to gravely damage the competitiveness of District heating. This will lead to a

situation where customers switch to cheaper unregulated alternatives, which will not only increase the

overall emissions of pollutants, but do so in emission points close to the ground, causing a severedeterioration of urban air quality.

- The first draft does not reflect the important principle of cost-effectiveness that should be central in thisprocess i.e. cost-benefit analysis of tightening emission limits, and inventory of alternative ways to

reach the same goal with other measures.

- The first draft does not reflect at this stage the complexity and diversity of the energy sector - range ofcapacities and technology types. And there is the need to do further work on the current draft and

consult stakeholders before adoption of a final document. No decision can be taken in a rush on such a

crucial dossier.

Need for comprehensive approach

Consistency with the principles set out in Directive 2010/75/EU on Industrial Emissions (IED) should besought in drafting ELVs. In particular, a more balanced approach would enable to focus not only on

consumptions of energy and water but also to account for the use of other entrants (chemicals). More

specifically, cross-media effects between emissions (air, water, residues) have to be considered when

stipulating BAT associated emission levels for one medium. The same applies to technical

interdependencies e.g. between carbon monoxide and nitrogen oxides emissions as well as ammonia

emissions from DENOX and the reduction of nitrogen oxides emission.

Link between IED and LCP BREF

The EIPPCB should clarify the link between BREF and current values set out in the Directive. This Directivewill require installations to meet new emission limits values by 2016. The implementation is under way, and

tenders concerning the construction of pollution control devices have started or will start in the next few

months. Shortly after the implementation of the IED, the implementation of BREF by 2018/2019 will oblige

operators to invest a second time into new technologies so that installations meet new ELV.

The EIPPCB should clarify that existing installations, which will comply with new requirements set out in the

IED, are exempted from implementing new emission limit values set out in BREF. There is urgency for

clarification on this issue to avoid stranded assets, uncertainty and misguided investments.

We propose that the BAT conclusions differentiate between:

New installations / major refurbishment (when the process is modernized). In this case, specificcombustion technologies, minimum energy efficiency performance should be required, along with

new AEL and new pollutants when applying for a permit

Installations where the process is not yet amortized, but the emission treatments already are. In thiscase, more stringent AEL / new pollutants should be required as long as they only involve amodernization of the emissions treatments

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Installations where the emission treatments units are not yet amortized. In this case, ELV should notbe lowered (i.e. stick to IED values for this present update and to the last BREF values for the future

ones) and new pollutants might be added as far as the corresponding requirements can be met with

the existing treatments.

Operating modes

The current draft addresses all plants disregarding operating modes. All plants operating mid-merit,emergency and peak load plants as well as industrial plants with repetitive quick changes in steam demand

are subject to the BREF on terms equal to those of base load plants of equal size and fuel. The requirements

of BATC on such plants might cause investments disproportionate to the gain in air quality, due to their

limited annual production. As written above, there is also a risk that such investments may lead to

increasing prices of district heat to a level that induces loss of customers - or even of entire nets, which in

turn means loss of previous gains in air quality and energy efficiency from CHP.

Measuring requirements

Last but not least, conclusions concerning measuring requirements should account of cost-effectivenessand account of past controlled impact on environment. For example it is not reasonable to monitor noise

level three times a year if previous tests have proved compliance with existing rules, nor is the suggested

frequency and extent of fuel analysis likely to improve the plants environmental performance compared tothe suggestion made by Euroheat & Power in our comment posted on BAT 5.

Derogation for peak installations

To minimize negative impacts on their economy, the IED authorizes Member States to use derogations(articles 31 to 35 and derogation for peak installation running less than l 500 hours in annex V). The IED is

unclear whether those derogations still apply or not, especially for peak boilers as the BREF is supposed to

replace annex V. The following principles should apply :

- The installations which got derogation should have to meet the associated emission levels of the BREFinto force at the end of their derogation deadline, provided that those requirements are published with

sufficient notice (publication at least 3 years prior to the deadline?)

- The BREF should not apply at all to peak installations. They should keep the current parameters /ELV ofthe IED.