National Programme for Ireland
under Article 6 of Directive 2001/81/EC for the progressive reduction of national
emissions of transboundary pollutants by 2010
1.0
Introduction
This document should be read in conjunction with the discussion paper on a Strategy to
Reduce Emissions of Transboundary Air Pollution by 2010 published by the Department in
June 2003. The discussion paper initiated a public consultation process with stakeholders,
inter alia, on the most appropriate policies and measures for Ireland to adopt to achieve its
commitments under directive 2001/81/EC to deliver the interim environmental objectives in
relation to acidification, health- and vegetation- related ground-level ozone exposure as set
out in Article 5. The discussion paper effectively constitutes a draft national programme as
required under Article 6 of the directive. Together with this document it now forms the final
national programme for Ireland to be reported to the Commission under Article 8 of the
directive.
The programme will be updated and revised as necessary by 1 October 2006 as required
by Article 6(3) of the directive in the light, inter alia, of:



2.0
on-going monitoring and review of the efficacy of implemented and planned policies
and measures,
improvements in emissions estimates for the inventory and projections,
the evolution of national projections for the main drivers of transboundary emissions
consistent with projections underpinning climate change policy.
Background
The environmental, health and legal backgrounds to directive 2001/81/EC as well as an
economic assessment and graphical profiling of various indicators of emission trends for
Ireland are presented in detail in the 2003 paper. It also describes the integrated approach
adopted in developing the national emission ceilings, which aims to exploit the potential for
synergies in tackling multiple environmental objectives simultaneously in a coordinated
balanced and cost effective manner. The analytical basis for the integrated approach was
provided by IIASA using the RAINS integrated assessment model1.
The discussion paper presented two scenarios for likely future emissions for 2010 and
these quantitative estimates form the basis for the final national programme but they will be
subject to a comprehensive review as part of the process to update and revise the
programme by 1 October 2006. The national programme now includes inventories for the
years 2002 and 2003 (see Annexe 2) available since publication of the 2003 paper.
1
IIASA (International Institute of Applied Systems Analysis) applied the Regional Acidification Integrations (RAINS)
model for the integrated assessment underpinning the original NEC directive.
2
3.0
Consultation Process
A total of twelve submissions were received in response to the discussion paper from a
range of stakeholders across the economy including, trade representative bodies,
environmental and business NGOs, electricity generators, Government Departments and
agencies, and one community group. A list of the respondents is provided in Annexe 1. All
submissions may be viewed in full on the Department’s website (www.environ.ie). The
submissions set out the views of certain key sectoral stakeholders in relation to the specific
pollutants, the national emission ceilings and the measures outlined in the paper.
Respondents generally welcomed the consultation process and recognised the need for
Ireland to fulfil its commitments under the directive and the importance of reducing the level
of tranboundary pollutant emissions to minimise damage to human heath and the
environment. Several respondents commented on the assumptions underpinning the
projections and one respondent from the electricity supply industry submitted alternative
estimates for likely future emission levels of SO2 and NOx. Several respondents highlighted
the need for an integrated approach to national policies to address emissions to air and in
particular highlighted the synergies with climate change policies. There was a general view
that for the pollutants SO2, NH3 and VOCs the measures outlined in the paper would
achieve the national emission ceilings.
The main focus of the submissions was in relation to NOx and its national emission ceiling
which it was generally agreed presents the most significant challenge for Ireland. Several
respondents highlighted national competitiveness concerns and the importance of adopting
a cost effective approach to implementing the directive at national level, in line with the
principle of the integrated approach underpinning the directive. One respondent proposed
that consideration should be given to seeking to rebalance the specific national NOx target
to avoid excessive costs for Ireland while still respecting the directive’s interim
environmental objectives, by adjusting the ceilings for the other acidifying emissions which
it is generally agreed can be more cost effectively achieved.
4.0
Progress and Developments Since Publication of Discussion Paper
This section outlines progress and significant developments that have occurred since the
publication of the 2003 paper and which need to be further considered in the national
programme as it is implemented over the period to 2010. In many cases definitive
quantitative estimates are not currently available but will be developed as appropriate for
the update and revision of the national programme in 2006.
4.1
Power Generation Sector
4.1.1 National Emission Reduction Plan (NERP) under Directive 2001/80/EC
Ireland has opted to develop a national emissions reduction plan (NERP) under Article 4 (6)
of the Large Combustion Plants directive (2001/80/EC)2 to address emissions from ‘existing
plant’ as defined in the directive. The NERP provides flexibility for plant operators to identify
the most cost effective abatement options available, across a portfolio of plant, while still
achieving the environmental objective of directive 2001/80/EC. The NERP option was
2
Large Combustion Plants Directive (2001/80/EC) on the limitation of emissions of certain pollutants into the air.
3
chosen because it provides both an environmentally ambitious and a cost effective
compliance route for Ireland. Many existing plant, particularly those in the electricity supply
industry will be operated at low load factor in the future to cater for reserve requirements
including back up capacity for wind generation. Low-load factor plant have limited potential
for emission reductions and make the installation of advanced abatement technologies very
costly per tonne of pollutant abated. Estimates developed in the preparation of the plan
indicate potential costs of up to € 50,000 per tonne of NOx abated for some existing plant if
the plant-specific emission limit value compliance route was chosen.
The NERP developed by Ireland sets limits for emissions of SO2 and NOx from existing
plant which are significantly more ambitious than the minimum requirements of directive
2001/80/EC. In the period from 2008 - 2016, the NERP is 27 % more ambitious for SO2 and
46 % more ambitious for NOx emissions. Detailed emission projections for SO2 and NOx
were developed by the interested sectoral operators in consultation with relevant
Government Departments and agencies to prepare the NERP using industry system
models based, inter alia, on merit order dispatch and catering for system constraints. The
NERP emission projection estimates vary from those included in the 2003 discussion paper
and further consultation will be required to inform ‘best’ estimates for the update and
revision of the national programme in 2006.
4.1.2
Commissioning of New Power Plant
Since publication of the discussion paper the Commission for Energy Regulation has
announced contracts for additional electricity generation capacity to be delivered by two
new state of the art gas fired plant, a 400 MW combined cycle gas turbine plant and a 150
MW CHP plant, both due to be operational by early 2006. The 400 MW plant will be located
in the west of the country which will help to address existing geographic network constraints
and the CHP plant will largely replace the existing oil fired boilers at the largest industrial
emitter of both SO2 and NOx in Ireland. These new plant will further reduce the NOx intensity
of electricity generation continuing the downward trend shown in Graph 17 of the discussion
paper and further decoupling NOx emissions from electricity generation.
4.2
Transport Sector
4.2.1 Sulphur free fuel excise differential
The discussion paper indicated that consideration would be given to the incentivisation of
sulphur free fuels for the full road transport market. To this end, on 1 December 2004
Ireland’s Budget 2005 indicated that an excise duty differential would be introduced to
incentivise sulphur free fuels. The excise duty differential will be introduced during 2005 and
should result in a total market switch to sulphur free petrol and diesel within a matter of
months. This will result in lower SO2, NOx and particulate matter emissions from vehicles,
improve the efficacy of advanced NOx abatement technologies and thus also promote
climate change policies to reduce greenhouse gas emissions by improving vehicle
efficiency. Total market conversion will place Ireland in the forefront of sulphur free road
fuels usage at least 3 years ahead of EU legal requirements.
4
4.3
Industry Sector
Major industrial installations in Ireland are regulated by the Environmental Protection
Agency (EPA) under the Integrated Pollution Prevention and Control (IPPC) directive
(96/61/EC). The directive has been in force since 1999 and requires that older installations,
existing before 1999, be licensed by October 2007. The EPA is currently reviewing
arrangements for these installations with a view to drawing up IPPC licences by the
required date. This will provide an opportunity to consider and apply appropriate emission
controls to reflect the best available techniques to these older industrial installations.
4.3.1 Feasibility Study of Advanced NOx Abatement in Cement Sector
The discussion paper indicated that consideration would be given to the application of
advanced NOx abatement techniques in the cement sector. The EPA in co-operation with
plant operators in the cement industry is currently assessing the feasibility of selective noncatalytic reduction (SNCR) abatement techniques in the cement sector. Since 2001 NOx
emissions from this sector have increased by 59% and by 2003, the cement sector
accounted for 57 % of total industry NOx emissions and 7% of total national emissions.
The EPA assessment is not yet complete but application of SNCR abatement techniques
could result in significant NOx savings. The Integrated Pollution Prevention and Control
BREF3 notes cite abatement performances for SNCR of 80% - 85% and indicate a cost for
SNCR of €0.6 per tonne of clinker produced. Assuming a more conservative abatement
performance of 60% the cost per tonne of NOx abated is € 400 per tonne.
4.4
Residential Sector
4.4.1 Solid Fuel Trade Group Voluntary Agreement
The voluntary agreement to reduce the sulphur content in coal and petcoke was signed by
the Minister for the Environment, Heritage and Local Government in 2002. To date the
agreement has been working well with sulphur levels for coal in the 2003/4 heating season
0.48 %, below the 0.7 % required by the agreement. The sulphur levels in petcoke
averaged 2.55 %, above the 2.0 % set out in the agreement. This resulted from a general
shortage of petcoke on the world market. The agreement is scheduled for review during
2005 and any revision to increase the ambition level will need to be included in the update
and revision of the national programme.
4.5
Agriculture
4.5.1 Full Decoupling under CAP
The discussion paper adopted a conservative approach to assessing likely future ammonia
emission reductions in 2010 as there was at that time a lack of certainty as to what
approach Ireland would opt for under the EU CAP reforms. Since publication of the
discussion paper, Ireland has formally opted for full ‘decoupling’ of direct support payment
and this is projected to result in significant decreases in the livestock population in the
period to 2010. It should be noted that the Luxemburg Agreement that provides the
framework for CAP reform is based on a ‘freedom to farm’ regime and so while reductions
in livestock numbers (and hence emissions) are highly likely they are not fully guaranteed.
3
BAT (Best Available Techniques) Reference Document known as BREF
5
Major revisions are currently underway to improve the methodology applied to ammonia
estimates in Ireland by moving to a more detailed estimation methodology. These revisions
will be finalised in the latter half of 2005 and applied to both the inventory and to the
updated projected activity data to inform the update and revision of the national
programme.
4.6
Cross-cutting Issues
4.6.1 Institutional Arrangements
Ireland made regulations in 20044 giving a national legal framework to Directive
2001/81/EC. The regulation provides a statutory basis for the preparation of the emission
inventories which will continue to be undertaken by the EPA. The regulation also provides a
statutory basis for emission projections, which for the first time will be undertaken by the
EPA on an annual basis to track progress towards the national emission ceilings by 2010.
To facilitate this work, arrangements are being put in place with the Government
Departments responsible for national energy and agriculture policy and statistics to provide
national projections for activity data for these sectors. Taken together the sectors
encompassed are responsible for the majority of total national emissions. The provision of
relevant data in a timely fashion is vital for the establishment of robust inventorying and
projections development. A national inventory system is currently being established to meet
the requirements for greenhouse gas reporting under the Kyoto Protocol and improvements
accruing from this system will be applied progressively to the transboundary emission
estimates.
4.6.2 Emission Inventories
Development of national emissions inventories is an ongoing process of continuous
improvement. Since the publication of the discussion paper in 2003 there have been a
number of improvements made to the estimates including the more extensive sourcing of
measured emission data from the industrial sector; improvement to methodology applied in
relation to aviation emissions and development of a methodology to quantify the effect of
fuel tourism. Ireland will formally submit an adjustment to the national inventory for the 2005
reporting cycle to reflect the effect of fuel tourism. Initially this adjustment will be applied to
the NOx inventory and then progressively to all affected emission estimates. As noted
above, work to revise the ammonia estimates from the agriculture sector is under way. A
review of VOC emissions from solvent applications, the single largest emission source, will
help improve the robustness of VOC emission estimates. Such improvements can result in
either an increase or decrease of the previous estimate though the ceilings in directive
2001/81/EC are set in absolute terms.
4.6.3 Emission Projections
Emission projections provide an analytical basis to inform the choice of the most
appropriate national policies and measures to be adopted and implemented to achieve
future emission levels. They depend on a wide range of assumptions, including, future
economic growth, structural changes in the economy, the penetration rate of cleaner
technology as well as global factors including world economic trends and international fuels
prices which are outside the scope of national influence. Their accuracy and efficacy can
4
European Communities (National Emission Ceilings) Regulations 2004 (S.I. No. 010 of 2004)
6
only conclusively be judged ex poste so it is important that they are reviewed on a regular
basis.
A number of policy developments noted above particularly in the power generation and
agriculture sectors require that the national projections be updated to reflect these
developments. National greenhouse gas projections to inform national allocations under the
EU CO2 emissions trading scheme for the period 2008 - 2012 will be developed in the
second half of 2005. It is considered important that updated projections to inform the update
and revision of the national programme are consistent with greenhouse gas projections
used to inform national climate change policy.
4.6.4 EU Review and Proposed Amendment of Directive 2001/81/EC.
The European Commission is currently reviewing Directive 2001/81/EC (as required under
Article 9) in the context of the Clean Air For Europe Programme (CAFE). The review is
based on revised analysis using integrated assessment modelling and updated data in
consultation with the Member States. The European Commission is also preparing a
separate new legislative proposal to revise both the national emission ceilings and other
aspects of the directive. This proposal will further develop the analytical work under CAFE
and is scheduled to be available by mid-2006. To further improve the integrated
assessment model, it is expected that bilateral consultations with Member States will
commence in April 2005 as this best fits with Member States’ obligations to prepare and
submit new projections of greenhouse gases under Decision 280/2004/EC on greenhouse
gas monitoring and reporting.
4.6.5 EU Emissions Trading Scheme for CO2 (EU-ETS)
The EU-ETS came into operation on 1st January 2005 and provides for emission trading of
CO2 amongst those installations covered by directive 2003/87/EC. The key economic
rationale behind emission trading is the use of market mechanisms to ensure that CO2
reductions take place where the cost of reduction is the lowest. Those Member States with
comparatively high CO2 abatement costs are likely to be net purchasers of carbon credits
as it will not be cost effective to make domestic emission reductions. Given the synergies
between CO2 and transboundary emissions reductions noted above, there are implications
for national transboundary emissions from the EU-ETS. There has been no assessment of
the likely effects of the scheme on transboundary emissions in Ireland though this will need
to be considered in the light of experience of the scheme in the update and revision of the
national programme
5.0
Update in Emission Trends
The national programme now includes national inventories for the years 2002 and 2003 in
Annexe 2 produced since the publication of the discussion paper. There has been a
progressive reduction of national emissions for all four NEC pollutants since 2001. With
regard to NOx emissions, Ireland will formally submit an adjusted inventory to reflect fuel
tourism as part of the 2005 reporting cycle. It is important from a national viewpoint to
understand the main domestic drivers of emissions in the transport sectors, so that
appropriate policies and measures can be designed to reduce emissions most effectively.
7
5.1
Sulphur Dioxide (SO2)
Total emissions of sulphur dioxide have been progressively reduced in recent years falling
from a high of 176 kt in 1998 to 76 kt in 2003. Between 2001 and 2003 total emissions have
fallen sharply by 40%, largely resulting from a 42% fall in the power generation sector
reflecting both the use of lower sulphur fuels and a move from heavy fuel oil to gas-based
generation. There were also significant falls in the industry and commercial sectors, down
54%, and 37% respectively for similar reasons.
Projections in the discussion paper suggest that the NEC for SO2 will be achieved on the
baseline5 scenario with further significant falls expected in the power generation and
industrial sectors. This projection appears to be confirmed by the trends evident in the
inventories of recent years.
5.2
Oxides of Nitrogen (NOx)
Current estimates for NOx emissions show that they have been progressively reduced from
a high in 2001 with a 7% reduction in 2002 and a further 4% reduction in 2003. The trend
reflects the continued decline in emissions from the power generation sector with the
introduction of new, more efficient generation plant and a change in fuel mix which resulted
in a sharp fall of 9% in emissions from the sector in 2002 and a further fall of 10% in 2003.
Emissions from the transport sector show a reduction of 5.2 % in 2002 and 5.6 % in 2003
following the introduction of more stringent Euro III vehicle emission standards6. Emissions
from the industry sector have risen in recent years, up 21 % on 2001, reflecting primarily
increased output from the cement sector.
The discussion paper presented a baseline scenario estimating total national emissions for
2010 of 94.0 kt. More recent estimates7 for equivalent scenarios provide estimates in the
range 93 kt – 100 kt. This is in contrast to the original baseline estimate of 70 kt.
underpinning the directive proposal. This significant revision to the estimate for the 2010
baseline has significant implications for the practicability of achieving the NOx ceiling. An
indication of this is that the more recent RAINS analysis8 indicated that the maximum
technical feasible reduction at 69.9 kt. is above the NOx ceiling.
Whereas the original analysis indicated that additional measures would be required to
reduce emissions from the baseline estimate of 70 kt. to 65 kt., the more recent analysis
implies that further additional measures would now be required to reduce emissions from
the revised baseline of c. 94.0 kt . to 65 kt. The further additional measures required would
involve further additional costs, over and above those envisaged at the time the national
emission ceiling was agreed. A robust assessment of any additional costs will be required
for the update and revision of the national programme in 2006.
The term ‘baseline’ is used here to denote the scenario which includes adopted or planned policies and measures. The
term “with measures”, used for greenhouse gas projections and defined in the UNFCCC reporting guidelines is used in
the discussion paper and can be considered equivalent to the baseline scenario and to the RAINS CLE scenario.
6
This data has not been adjusted to reflect the effect of fuel tourism (see para. 57 of 2003 discussion paper). An
adjusted inventory will be submitted to UNECE as part of the 2005 reporting cycle.
7
Estimates contained in consultation submission (2003), EPA/SEI study (2004) and RAINS BL_CLE_Aug04(Aug04).
8
RAINS CP_ MFR_Nov04(Nov04)
5
8
5.3
Volatile Organic Compounds (VOCs)
Total emissions for VOCs have been progressively reduced in recent years falling from a
high of 117.74 kt in 1999. Between 2001 and 2003, total emissions fell by10% from 86.7kt
to 77.8 kt reflecting a decrease in both tail pipe and evaporative emissions in the road
transport sector.
Projections in the discussion paper suggest that the national emission ceiling for VOCs
could be achieved by implementing additional measures to abate emissions from vehicle
refuelling. It should be noted that the VOC inventory (and hence the projection) is
considered uncertain and, as indicated above, further research is to be conducted to
improve its robustness.
5.4
Ammonia (NH3)
Total emissions for ammonia have been progressively reduced in recent years falling from
a high of 127 kt in 1999. In 2003 the agriculture sector was responsible for 98% of all
ammonia emissions. Between 2001 and 2003 emissions fell by 5% and further reductions
can be expected in line with projected livestock reductions associated with the
implementation of full decoupling.
Projections in the discussion paper indicate that the national emission ceiling for ammonia
will be achieved on the baseline scenario with the estimate for 2010 returning
approximately to 1990 levels. As noted above, a conservative approach was taken to the
estimation of likely future emission reductions from the sector and the projection will need to
be revised for the update and revision of the national programme.
6.0
National Emission Ceiling Challenge for Ireland
As can be seen from the previous section, Ireland has achieved progressive reductions in
emissions of all four pollutants in the period 2001 to 2003 and current best estimates for
projections indicate that the NEC targets for SO2, ammonia and VOCs set out in Annex I of
the directive should be cost effectively achieved. However, it is clear that the NOx ceiling
presents a significant difficulty for Ireland and that measures to achieve the specific ceiling
could be disproportionately costly.
Recent integrated assessment modelling conducted for the CAFE programme using
updated data sets for Ireland and other Member States indicates a revised 2010 baseline
estimate for Ireland for NOx which is comparable to that presented in the 2003 discussion
paper. More recent national estimates were also comparable.
The analysis for the original directive proposal assumed a baseline scenario (known as the
‘REF’ scenario) significantly below this at 70kt and a modest additional cost to achieve the
original proposed NOx ceiling of 59 kt. Based on the analysis for CAFE (August 2004), the
potential cost to Ireland of achieving the NOx ceiling in the directive has increased very
significantly and it seems clear that the NOx ceiling does not represent a cost effective route
for Ireland to make its contribution to the attainment of the directive’s interim environmental
objectives.
9
A recent preliminary national study9 reviewed the current data for Ireland for the integrated
assessment model and highlighted some areas where the data sets could be further
improved to better reflect national circumstances. Clearly, it is crucial that data sets should
be robust if the model is to develop cost effective ceilings for Member States. It is intended
to further develop this preliminary study to ensure that data for Ireland is as robust as
possible to provide a robust and cost effective basis for future national emission ceilings.
7.0
Conclusion
The national programme for Ireland has been compiled to comply with the requirements of
Article 6 of Directive 2001/81/EC. There has been a progressive reduction of national
emissions for all four NEC pollutants since 2001, which reflects the on-going
implementation of policies and measures outlined in the discussion paper. This document
sets out a number of significant developments in policies and measures in the power
generation, transport, industry, and agriculture sectors since the 2003 paper. The
downward emissions trend evident since 2001 is projected to continue to 2010, though it is
clear that the NOx ceiling as set out in Annex I of the directive presents a significant
difficulty for Ireland and that measures to achieve the specific ceiling could be
disproportionately costly.
The legislative proposal to revise the national emission ceilings and other aspects of the
directive by mid-2006 will, as before, be based on integrated assessment modelling and
consultations to update the model are due to commence with Member States in April 2005.
It seems clear, based on available updated data sets, that the current ceilings for Ireland do
not represent the most cost effective route for Ireland to make its contribution to meeting
the directive’s interim environmental objectives. It is anticipated that this will become
evident during the analytical preparations for the new legislative proposal.
This National Programme will be updated and revised as necessary in 2006 to take account
fully of all relevant policy and legislative developments particularly the proposal to revise the
national emission ceilings and other aspects of the directive.
9
Preliminary study to develop and validate input data for integrated assessment modelling for Ireland under the CAFÉ
Programme. EPA/SEI (2004)
10
ANNEXE 1
RESPONDENTS TO THE 2003 DRAFT STRATEGY
Commission for Electricity Regulation
Department of Agriculture and Food
Department of Communications, Marine and Natural Resources
Department of Enterprise, Trade and Employment
Electricity Supply Board
Friends of the Irish Environment
Greenhouse Ireland Action Network (GRIAN)
Irish Business Employers Confederation
Solid Fuel Trade Group
Sustainable Energy Ireland
United Portmarnock Residents Opposed to Another Runway (UPROAR)
Viridian Power and Energy
11
ANNEXE 2
2002 Final and 2003 Provisional National Emission Inventories
2001
2002
2003
Amounts in Kt
Sector
Combustion in Energy & Transformation Industries
Non-Industrial Combustion
Combustion in Industry
SO2
77.2
21.9
22.8
Production Processes
NOx
42.0
7.9
12.7
0.4
NH3
0.0
49.8
22.1
1.9
0.1
Extraction and Distribution of Fossil Fuels
Solvent and Other Product Use
Road Transport
Other Mobile Sources and Machinery
1.7
2.4
VOCs
0.3
5.1
0.5
1.4
5.3
34.8
33.3
2.8
SO2
62.0
16.4
14.6
1.5
1.8
NOx
38.5
7.8
14.1
0.2
NH3
0.0
47.3
17.5
2.2
0.0
VOCs
0.3
5.0
0.5
1.2
5.5
35.0
28.1
2.3
SO2
45.0
17.8
10.6
1.5
1.5
NOx
34.4
7.8
15.3
0.0
NH3
0.0
44.6
17.6
2.2
0.0
VOCs
0.2
4.3
0.5
1.3
5.5
35.6
24.9
2.3
Waste Treatment and Disposal
Agriculture
Total
126.1
134.9
120.6
3.4
122.7
87.0
96.2
125.3
116.8
3.5
119.0
81.4
76.4
119.8
114.0
3.4
116.3
77.8