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Polish emission trading project Integration with IPPC directive

Polish emission trading project Integration with IPPC directive. CATEP meeting Brussels , 22 may 2003 Bolesław Jankowski, Systems Research „EnergSys”, Coordinator of emission trading project in Poland boleslaw.jankowski@energsys.com.pl. Main points. 1. Motivation and goals

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Polish emission trading project Integration with IPPC directive

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  1. Polish emission trading projectIntegration with IPPC directive CATEP meeting Brussels , 22 may 2003 Bolesław Jankowski, Systems Research „EnergSys”, Coordinator of emission trading project in Poland boleslaw.jankowski@energsys.com.pl

  2. Main points 1. Motivation and goals 2. General concept of the Polish emission trading programme 3. Integration of emission trading and IPPC 4. Conclusions

  3. Motivation and goals (1)Legal framework Driving forces • Poland ratified the Kyoto protocol (GHG) • LCP directive (2001/80/WE) to be implemented • Treaty of Accession • SO2 and NOx emission limits for LCP group • SO2 and NOx emission limit for the country (as in Gothenborg Protocol) Constraints • IPPC directive (emission limit values according BAT) • Framework directive 96/62 on ambient air

  4. Motivation and goals (2) Main policy problems related to SO2 emission • 5 921 million Euro investments in Poland for SO2 emission reduction in 1990 - 2005 • Very high costs of the LCP directive implementation (investments outlays 11 800 - 12 600 million Euro and electricity production cost increase by 33% in 2016) • Transitional periods could reduce compliance costs (investments to 6 300 million Euro and electricity production cost increase by 25% in 2016) • Emission limits from Treaty of Accession for the whole LCP group are more stringent then LCP directive with transitional periods • High electricity cost increase will generate social problems

  5. Motivation and goals (3)SO2 and NOx emission limits for LCP group

  6. Motivation and goals (4)Main goals for SO2 emission trading • Reduction of costs of compliance with the current EU requirements • implementation the LPC directive by means of the National Emission Reduction Programme in emission trading mode instead of the emission standards (existing installations) • implementation of emission trading to achieve further emission reduction and to meet Treaty of Accession goals • Creation of the flexible mechanism which can be used for effective realisation of the future emissionreduction goals in Poland

  7. General concept (1)The structure of the emission trading programme Advantages: - significant common part of legal and institutional infrastructure in case of different emission trading programmes - possibility to introduce new emission trading programmes with relatively low effort and costs

  8. General concept (2)Emission trading of SO2 in the Polish system of air protection

  9. Integration of emission trading and IPPC (1)Effect and technology driven policies • Effect driven policy: • National emission limits of SO2 and NOx (e.g. Gothenborg Protocol, NEC directive) • Ambient air quality standards and related instruments (96/62 and daughter directives) • Technology driven policy: • LCP directive • IPPC directive (BAT)

  10. Integration of emission trading and IPPC (2)Conflict between different approaches • In case of SO2 and NOx effect driven instruments cover the whole range of environmental problems (trans-national and local) • As effect driven instruments are becoming more consequently introduced, technology driven instruments are becoming redundant and conflict to them

  11. Integration of emission trading and IPPC (3)Interrelation between different instruments

  12. Integration of emission trading and IPPC (4)Interrelation between different instruments How to integrate the following instruments: • Emission trading <-> LCP directive • Emission trading <-> IPPC directive • LCP <-> IPPC directive Main problem: • very stringent individual emission standards or limits (non tradable permit) could “kill” economic efficiency of emission trading

  13. Integration of emission trading and IPPC (5)Emission trading <-> LCP directive Main assumptions in the Polish project: • In case of existing emission sources the LCP directive allows for implementation of the National Emission Reduction Plan (NERP) instead of more stringent emission standards from 2008 • NERP could be implemented by introduction of emission trading system and by leaving the emission standards in existing sources as they were before Conclusion: • LCP seems not to be in conflict with emission trading, mechanism of NERP could be even considered as a good legal base for emission trading implementation

  14. Integration of emission trading and IPPC (6)Emission trading <-> IPPC directive, LCP <-> IPPC Emission trading seems to be in conflict with IPPC directive, however: • LCP directive can not be in conflict with IPPC directive • In case of SO2, NOx emissions from large combustion plants the LCP directive requirements could be treated as being consistent with technological requirements of IPPC (BAT) • Implementation of NERP for SO2 and NOx based on LCP directive provisions could be treated as consistent with BAT requirements in IPPC Conclusion: • Implementation of emission trading as an instrument of NERP realisation (only existing installations) logically seems not to be in conflict with IPPC

  15. Conclusions (1) 1. Emission trading in Poland allow for meeting the UE emission requirements for large combustion plants by significantly lower costs 2. The local impact of emission sources participating in SO2 emission trading system will be controlled by other instruments based on ambient air quality standards 3. Emission trading could be effectively implemented: (i) to achieve the national emission limits as e.g. from NEC directive, (ii) to achieve by significantly lower costs the same emission reduction as by tightening emission standards in existing emission sources (as allowed in LCP directive and in the Gothenburg Protocol) (iii) as an element of local air quality management particularly for emissions characterised by high rate of inter-regional transport (it is difficult to control local SO2 and NOx concentrations only by controling local sources)

  16. Conclusions (2) 4. Expected future tightening of the national emission limits of SO2, NOx, VOC, NH3, heavy metals in EU-25 is a good argument for creating legal base for emission trading in EU countries also beyond GHG 5. Wider use of effect oriented approach in air protection in EU (e.g CLRTAP protocols, NEC directive, ambient air quality control) requires eliminating potential conflicts between this approach and technology oriented instruments (LCP and BAT in IPPC) 6. Efficient implementing of SO2 and NOx emission trading (ET) in Poland requires exclusion of installation participating in ET from BAT requirements as defined in IPPC directive 7. IPPC should be more flexible in application of BAT, particularly in respect to existing installations - to allow for using emission trading as an alternative to the tightening of emission standards (such alternative is allowed in LCP directive and in Gothenburg Protocol)

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