Large Combustion Plants (LCP) are the most significant point source emitters of air pollution in Europe. The LCP BREF covers the combustion plants with a thermal input above 50MW, covering about 3,200 single large combustion plants.
According to the report Costs of air pollution from European industrial facilities 2008–2012 (EEA), the 1,600 facilities grouping either single or combined LCPs make up 57% (44.7bn €) of the total air pollution damage costs, despite representing only 11% of the facilities assessed (14,325). With a very few exceptions, all the worst 147 air polluters are LCPs, and they are responsible for over 50% of the damage costs, despite representing only 1% of the EU facilities assessed.
LCPs burning solid fuels, and notably lignite and coal, are not only the worst climate offenders, they are also the largest source of SO2 and mercury emissions in Europe, and one of the main sources of NOx and other heavy metals. Of the 30most health-damaging industrial installations identified in the EEA’s report, 26 are coal or lignite fired LCPs. The health impacts of coal-fired LCPs are estimated at more than 16,150 premature deaths, about 7,600 extra cases of chronic bronchitis and over 4.8million lost working days each year in the EU and Western Balkans.
The reviewed EU LCP BREF standards provide opportunities to accelerate the energy transition, as it could trigger important investment decisions in terms of air pollution controls, prior to 17 August 2021.
Process and status
The first LCP BREF took place as from 2000 and was adopted in 2006 under the IPPC Directive framework. The main positive impact was forcing Flue Gas Desulphurisation (FGD) on coal/lignite combustion, and secondary DeNOx controls for hardcoal plants (at that time only SCR), as well as dust controls on solid fuel combustion.
However, many member states ignored those standards due to be complied with by 2008, and instead prolonged derogations beyond BAT standards by making use of optional derogations allowed under Chapter III of the Industrial Emissions Directive, notably the Transitional National Plan (2016 – July2020). More information on those derogations for the electricity generating coal/lignite LCPs are available in the ‘Lifting EU’s Dark Cloud’ report with the Full plant results, as well as the EEB’s Industrial Plant Data Viewer (IPDV) for all LCPs.
The 2006 IPPC LCP BREF was revised between January 2011 and September 2015. Its review was was probably the most politically charged ones, alongside the Refineries BREF’s.
The IED Forum took place on 20 October 2016 (IED forum meeting notes are available here). Ahead of that meeting, Ministries from Poland, the Czech Republic, Greece, Finland and the UK attempted to introduce a further delay by requesting the European Commission to make an “impact assessment”, as requested by the industry (the Ministries’ letter to the European Commission is available here). The EEB objected to this (EEB objection). Minor changes were made to the final draft, some of which include EEB suggestions; the other EEB recommendations which did not meet consensus are available here.
Finally, a favourable vote took place on 28 April 2018 without the impact assessment. The vote passed by a very tight 0,14% margin, as all lignite addicted countries except from Greece voted against to protect the interests of the lignite industry, and the Finnish government objected because it wanted relaxation on biomass and peat combustion (the Voting results and the EEB’s Press Release are available here).
The Government of Greece did at the end vote in favour because it received a concession for phasing-in stricter air pollution controls on heavy fuel oil fired engines located on islands being part of a small isolated/micro system only as from 2030 for existing engines under the following conditions:
a) The operator must make the case that secondary abatement is not possible due to technical, economic and logistical infrastructure constraints;
b) The interconnection to the mainland electricity grid or access to natural gas supply is still pending.
The LCP BREF BAT Conclusions were finally published in the Official Journal of the European Union on 17 August 2017. The Full Revised LCP BREF is available here.
The deadline for compliance is by 17 August 2021, permit reviews are therefore ongoing.
In very rare cases, transposition is also taking place through General Binding Rules, like for Germany. The draft law however foresees a 1:1 implementation of the lowest common EU denominator, which triggered significant critique by the EEB and its members (the EEB position and the EEB members’ position, in German, are available here).
Main environmental issues and discussion points on BAT / BAT-AELs
The main focus for the EEB was the cutting of air pollution from solid fuel combustion, in particular from existing coal and lignite LCPs. The specific focus was therefore on the following aspects:
- Forcing SCR on existing coal/lignite boilers (upper NOx BAT-AEL set to 100mg/Nm³);
- Limiting the BAT-AEL of dust to maximum 3.5mg/Nm³;
- Preventing an indirect subsidy for firing high sulphur lignite/hardcoal by scrapping the desulphurisation rate approach (Czech industry led domestic fuel initiative), banning the combustion of >3,25% Sulphur content in fuels, limiting the upper BAT-AEL for SO2 to 130mg/Nm³ for 1-3,25% S content and to 40mg/Nm³ for <1% S content;
- Requiring dedicated mercury abatement controls by setting a BAT-AEL level to 1µg/Nm³ (annual average) for plants >300MWth and up to 3.5µg/Nm³ for plants <300MWth, as well as continuous emissions monitoring;
- Requiring stricter NOx levels on biomass and peat combustion, also to prevent coal boilers to convert to biomass combustion.
Other requests, such as the promotion of electro-boilers as heat storage buffers in CHP plants was considered by other stakeholders as out of the scope. The LCP BREF also provided improvements in relation to limiting water emissions to surface waters (in particular for mercury and cadmium), as well as tightening the requirements on energy efficiency.
This BREF was also very politically charged, which led to an infiltration of the member states delegations by operators of LCPs, as exposed in Greenpeace’s ‘Smoke and Mirrors’ report, (a Joint policy briefing by the EEB and Greenpeace is available here.) More details on the various positions expressed by the EEB are available at the following documents:
- EEB draft 1 comments, submission on Domestic Fuel Initiative (high sulphur lignites)
- EEB letter to Commissioners and Annex to the EEB letter to Commissioners, further Comments to the EIPPCB in advance of the Final meeting of the Technical Working Group in Seville with attachments and full set of comments made during the final meeting
- Joint study by the EEB and Greenpeace (2015) on the impact that differentiated pollution standards could have in terms of avoiding External health costs. Country specific results have also been produced
- Green 10 letter to Commissioner Vella requesting fast adoption process, and Commissioner Vella’s response
- EEB set of split views made after the Final LCP BREF meeting and LCP BREF webinar
- EEB letter to the Environment Commissioner ahead of the IED Forum meeting and Comments on pre-final LCP draft, as well as Comments submitted for the Forum
- Joint NGO report ‘Lifting Europe’s Dark Cloud (2017), with Country fact sheets and a List of coal/lignite plants and health impacts under each plant specific compliance scenarios (2013 situation, less strict BREF upper range, true BAT stricter emissions range).
How can you make a difference
The EEB has provided an updated Background briefing on the 2017 LCP BREF transposition for coal-fired power plants, specifically targeting the implementation of the LCP BREF currently ongoing, in particular for coal and lignite plants >300MWth and specifically in relation to NOx emissions (the NOx emissions briefing is available here).
The main impact expected is on NOx and mercury for existing lignite plants. Germany is primary target and therefore you can support the points made notably in the EEB 2017 study on German coal power plants (mercury and NOx focussed study) as well as EEB 2020 input made for the 13. BImSchV review implementing the LCP BREF, still ongoing.
Wider LCP emission data beyond coal fired plants is made available on the Industrial Plants Data Viewer (IPDV), which also lists pending or granted derogations. Many data gaps still exist, and we seek for collaboration from various stakeholder groups.
The EEB is member of the Europe Beyond Coal campaign, and we therefore welcome any support in achieving the 2030 Europe wide coal phase out goal, however we also see no role for gas in that transition.
Due to the wrong setup of the scope of the Industrial Emission Directive we would not wish a review of the 2017 LCP BREF but to replace if by an “Energy Generation BREF”, assessing all the available options for the BAT assessment. We therefore plan to draft our own “Energy Generation BREF” and look forward for contributions.
The EEB staff will also focus its attention on water quality and quantity relevant aspects due to thermal power and lignite mining activities.
Christian.Schaible@eeb.org (Energy Generation BREF)
Riccardo.Nigro@eeb.org Campaign coordinator: coal combustion and mines
Goran.Kovacevik@eeb.org (LCP BREF implementation, technical issues)
Sara.Johansson@eeb.org and Jai.KrishnaR@eeb.org (Water-Energy-Mines Nexus)