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Updated:Tuesday, July 29, 2014 - 10:50
EHI position and engagement
EHI represents manufacturers of all heating systems, including industrial and commercial installations, and is currently following the developments regarding the draft Directive on the limitation of emissions of certain pollutants into the air from medium combustion plants. EHI supports to lay down rules to control emissions from 1-50 MWth installations covering combustion plants, engines and gas turbines, with different emission limit values for existing and new installations. Registration of medium combustion plants will also help develop the European statistics on this sector.
For this purpose, EHI proposes the following recommendations:
- Setting proportionate emission limit values for existing and new combustion plants, values which should leave the door open for companies to apply measures to increase energy efficiency of medium combustion plants.
- Taking into account that there has to be a differentiation of the appliance size regarding the output range and to distinguish between smaller and bigger plants, e.g. between 1-10 MW and 10-50 MW.
- Not allowing Member States to apply more stringent emission limits in certain zones with air quality issues. Very low benchmark values for more stringent emission limits can only be reached by the best available technologies, which only represent about 1 – 5 % of the market, and has to be judged carefully taking into account the special requirements of each installation. Very ambitious emission limits can only be reached from the majority of the best appliances by secondary measures which would exponentially raise the appliance/installation cost. Setting stricter emission limits locally would be disproportionate to the objective of improving air quality zones and would unfairly discriminate against medium size combustion plants, which are not the only emission source in these zones.
- Taking into account the on-going discussion on the future European gas qualities, especially the fluctuations of these gas qualities. EHI has strong concerns that with the currently discussed future gas qualities, all gas fired appliances will not be able to reach stricter limits. The fluctuations make it necessary that the appliance could not be adjusted as today optimised on safety issues, for efficiency and minimize emissions as they need more distance to each of the optimal installation adjustments.
On 18 December 2013, the Commission adopted a clean air policy package, containing:
- A new Clean Air Programme for Europe with measures to ensure that existing targets are met in the short term, and new air quality objectives for the period up to 2030. The package also includes support measures to help cut air pollution, with a focus on improving air quality in cities, supporting research and innovation, and promoting international cooperation
- A revised National Emission Ceilings Directive with stricter national emission ceilings for the six main pollutants , and
- A proposal for a new Directive to reduce pollution from medium-sized combustion installations, such as energy plants for street blocks or large buildings, and small industry installations.
The Europeaan Commission conducted a review of the EU Thematic Strategy on Air Pollution (TSAP) and its associated policies, including a broad consultation process, with the organisation of a series of Stakeholder Expert Groups as well as public consultations.
The European air pollution policy has a long history, with the most recent wave of policy launched in 2005 with the Thematic Strategy on Air Pollution designed to make substantial progress towards the long-term EU objectives.
Ambient air quality
Directive 2008/50/EC on ambient air quality and cleaner air for Europe including the following elements:
The merging of most of existing legislation into a single directive (except for the Fourth Daughter Directive) with no change to existing air quality objectives.
New air quality objectives for PM2.5 (fine particles) including the limit value and exposure related objectives – exposure concentration obligation and exposure reduction target.
The possibility to discount natural sources of pollution when assessing compliance against limit values.
The possibility for time extensions of three years (PM10) or up to five years (NO2, benzene) for complying with limit values, based on conditions and the assessment by the European Commission.
Council Directive 96/62/EC on ambient air quality assessment and management (Air Quality Framework Directive).
Council Directive 1999/30/EC relating to limit values for sulphur dioxide, nitrogen dioxide and oxides of nitrogen, particulate matter and lead in ambient air (First Daughter Directive).
Directive 2000/69/EC of the European Parliament and of the Council relating to limit values for benzene and carbon monoxide in ambient air (Second Daughter Directive).
Directive 2002/3/EC of the European Parliament and of the Council relating to ozone in ambient air (Third Daughter Directive).
Directive 2004/107/EC of the European Parliament and of the Council relating to arsenic, cadmium, mercury, nickel and polycyclic aromatic hydrocarbons in ambient air (Fourth Daughter Directive).
Council Decision 97/101/EC establishing a reciprocal exchange of information and data from networks and individual stations measuring ambient air pollution within the Member States (EoI Decision).
Commission Decision 2004/461/EC laying down a questionnaire for annual reporting on ambient air quality assessment under Council Directives 96/62/EC and 1999/30/EC and under Directives 2000/69/EC and 2002/3/EC of the European Parliament and of the Council.
Commission Decision 2004/224/EC laying down the obligation of Member States to submit within two years so-called Plans and Programmes for those air quality zones where certain assessment thresholds set in the Directives are exceeded.
Stationary Source Emissions
Integrated Pollution Prevention and control
- Council Directive 2008/1/EC of 15 January 2008 concerning integrated pollution prevention and control(IPPC)
- Directive on industrial emissions 2010/75/EU (IED) - to replace the IPPC Directive and the sectoral directives as of 7 January 2014, with the exemption of the LCP Directive, which will be repealed with effect from 1 January 2016
Large Combustion Plants
Directive 2001/80/EC on the limitation of emissions of certain pollutants into the air from Large Combustion Plants
- Council Directive 94/66/EC amending Directive 88/609/EEC on the limitation of emissions of certain pollutants into the air from large combustion plants
Waste Incineration Plants
Directive 2000/76/EC of the European Parliament and of the Council of 4th December 2000 on the incineration of waste.
National Emission Ceilings
Directive 2001/81/EC on national emissions ceilings for certain atmospheric pollutants