Consultation Paper on the implementation of the revised Large Combustion Plant Directive
DRAFT UK NATIONAL PLAN UNDER THE REVISED LARGE COMBUSTION PLANTS DIRECTIVE (2001/80/EC) Annex C to the June 2003 consultation paper
Introduction
1.1 This document
This is the United Kingdom's national plan for 'existing' plants - that is plants for which a licence was granted before 1 July 1987 - under the revised Large Combustion Plant Directive (2001/80/EC, LCPD). The document is structured as follows:
Section 2 introduces the profile of existing plants in the UK and relevant operational performance data;
Section 3 presents the calculation of the parameters defining the national plan, expressed as total emission 'bubbles' for SO2, NOx and dust;
Section 4 identifies the approach that the UK will be taking to ensure compliance with the objectives;
Section 5 presents a provisional timetable for reaching the objectives;
Section 6 presents the monitoring mechanism; and
Section 7 presents a glossary of terms.
The national plan has been developed based on a UK-wide plant-by-plant assessment of key operating performance characteristics to enable an accurate determination of the objectives of a national plan and corresponding compliance measures.
It takes into account the current status of plants, our interpretations of the requirements of the LCPD, and the European Commission's guidance on what should be covered by a national plan.
1.2 Working Assumptions
1.2.1 The meaning of combustion plant
The Directive provides that a combustion plant may include more than one unit, where they could discharge through a 'common stack'. However, the Directive does not expressly provide what should be understood as a 'common stack' for existing plants for the purposes of that definition The way in which many existing power stations are constructed does not help towards the interpretation of this provision since many stations have a number of boilers and several flues that vent waste gases to the atmosphere.
- In one view (the 'station' approach) what people commonly call the 'chimney' for a power station should be regarded as just that: one chimney, one common stack, one plant. In this view, all the boilers, and turbines associated with all of the flues should be regulated under the Directive as a single plant.
- In the other view (the 'unit' approach) each flue (which may be connected to several boilers) is taken as a 'common stack'. What in the 'station' view is called a chimney is in fact a weather-shield that protects the flues from the elements and provides stability. Multiple flues show separately at the top of the weather-shield. The flues are close together both to limit the visual impact and for operational reasons, but the 'units' operate independently: multiple flues, multiple common stacks, multiple plants. In this view, all the boilers, and turbines associated with each separate flue should be regulated under the Directive as a plant in its own right.
The UK is adopting the 'unit' approach. We consider that this interpretation is, as a matter of law, in accordance with the requirements of the Directive.
1.2.2 The meaning of operational hours in the context of the limited hours derogation and the low load factor derogations
The UK considers that start-up and shut-down periods should not be taken into account for the purpose of calculating the operational hours in relation to Article 4 (4), Article 4 (6), Article 5 (1) and Note 2 to Part A of Annex VI of the LCPD.
1.2.3 Dealing with plant closures in a national plan
If a plant closes, the Directive requires there to be no increase in the total annual emissions from the remaining plants covered by the plan. We have assumed an interpretation that this means that when a plant closes, the overall national plan limits for SO 2, NO x and dust - the so-called 'bubbles' - will have to reduce by the size of the contribution the closing plant made to the original calculation of these 'bubbles'.
1.2.4 Other interpretation issues
We set out at [annex to the consultation paper] several other interpretation issues that also have a bearing on the UK's approach to the implementation of the LCPD in relation to existing plants. We specifically want to draw these interpretations - as well as those set out above - to the attention of the Commission. We would ask the Commission to consider our interpretations and to confirm that they are content with them, in their formal response to this draft national plan.