emissions performance standard briefing for house of lords - e3g
TRANSCRIPT
Emissions Performance Standard Briefing for House of Lords consideration of
Energy Bill, Amendment 105
Recommendation
Existing coal plants should be included under the Emissions Performance Standard (EPS) if
they seek to extend their operating life, as proposed by Amendment 105. This would close
a loophole in the original EPS proposals and provide a timetable for phased reductions in
emissions from the oldest and most inefficient coal power plants over the next decade.
Summary
At report stage, the House of Lords voted to include existing coal plants within the scope of
the EPS if they were to upgrade to meet air pollution requirements, thereby enabling
operation at high load factors beyond 2016 and throughout the 2020s.
In a vote on 4th
December, the House of Commons rejected this amendment by 318 votes to
236. The House of Lords must therefore reconsider whether this issue should be returned to
the Commons for a second time. Annex 3 below provides details of the arguments made
against the amendment by the government. These are seen to be contradictory.
There is a significantly increased risk that existing coal plants will upgrade to meet the air
pollution requirements of the Industrial Emissions Directive (IED). The investment case for
the life extension of existing coal plants is being encouraged by current government policy: it
proposes that these plants would be exempt from the proposed Emissions Performance
Standard (EPS) and able to lock-in three years of receipts from the capacity mechanism.
In addition to its negative impact on power sector decarbonisation, this will also result in
adverse outcomes for security of supply and affordability, by:
> Disincentivising investment in new gas plant and continued mothballing of existing gas
generation assets, with increased dependence on old coal plant.
> Requiring higher capacity payments to support gas generation, without any positive
impact on wholesale prices, which currently provide high returns to coal plant operators.
The government already accepts that any existing coal plant that undertakes major
technology upgrades to improve operating efficiencies and extend plant lifetimes should be
included under the EPS. This same principle should be consistently applied to any plant that
upgrades pollution control equipment in order to meet the IED, which also extends its
working life.
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Affordability1
The wholesale electricity price is set by the costs of gas generation. The lower cost of coal
generation results in increased returns for coal plant operators, but no positive impact on
consumer prices. If little or no coal capacity were to opt in to the IED, it can be expected
that the foregone additional coal generation will be replaced by additional generation from
more efficient (probably new) gas plant and therefore the marginal gas plant and electricity
prices will remain essentially unchanged.
The continued operation of existing coal plant will also have an impact on costs to
consumers. Analysis by Simon Skillings (formerly Director of Policy and Strategy for E.ON UK)
finds that “new gas-fired generators will demand a higher price from the capacity
auctions to proceed with new build projects if significant proportions of coal plant opt-in
and, given the market-wide nature of the capacity mechanism, this could significantly
increase costs to consumers in delivering the required reliability standard.” 2
Security of Supply
The IED incorporates long lead times and flexibility mechanisms in order to provide sufficient
time for new investment and avoid impacts to security of supply. The inclusion of existing
coal plants under the UK’s EPS would use the same timetables that are already in place and
there is no immediate ‘cliff edge’ threat to security of supply.
> 1 Source: Committee on Climate Change, 2013 Progress Report to Parliament
2 The future of existing coal plant in GB and implications for security of supply and affordability,
Trilemma UK, October 2013
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In the event that plant operators decide not to upgrade (and therefore not fall under the
EPS) the IED will permit ‘opted out’ plant to undertake 17,500 hours of operations between
01/01/2016 and 31/12/2023. Simon Skillings’ analysis states that “system security in the UK
is likely to be increased rather than reduced if existing coal plant opts out of the
provisions of the IED, as the operating potential for new and existing gas plant would be
improved, while sufficient coal plant would remain available for winter peak operations
beyond 2020.”
Achievability3
Achievable emissions intensity is the carbon intensity of electricity supply that would be
achievable if power plants were dispatched in order of least emission rather than least cost,
while still maintaining security of supply to keep the lights on. This indicator shows that there
is scope to reduce current emissions intensity by over 200gCO2/kWh (41%) within existing
capacity through fuel-switching, primarily from coal to gas. This is achievable while
maintaining security of supply at minimal cost to the consumer, being available today
without any requirement for new investment, and given that the market electricity price
continues to be set largely by gas plant.
Rationale for amendment to the Bill
Schedule 4 of the Energy Bill includes provisions that would apply the EPS to existing plants
that upgrade boilers to improve plant efficiencies and extend plant life.
This same principle should also be applied to plants seeking to extend operating lifetimes via
the installation of other pollution control equipment, for example to meet the Industrial
Emissions Directive beyond 2023. Such investments are being actively considered by
> 3 Source: Committee on Climate Change, 2013 Progress Report to Parliament
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operators, and are currently attractive options due to low prices of coal and carbon that
have made coal plants more profitable over recent years.
The government has previously argued that the incorporation of existing plants under the
EPS is not required due to the existence of price incentives that would result in a switch from
coal- to gas-fired generation. However the collapse of carbon prices under the EU ETS and
the perceived political instability of the UK’s unilateral carbon price support mechanism
mean that this is currently not taking place.
As a consequence, the International Energy Agency has recommended that EU member
states should actively look to non-price measures to ensure the retirement of old coal plant.4
Existing processes require decisions by operators as to whether they intend to invest in plant
upgrades to meet the Industrial Emissions Directive. These timetables provide the
opportunity for existing plants to be incorporated into the scope of the UK EPS in a coherent
manner without requiring retrospective regulatory measures.
The approach taken by the proposed amendment is therefore in line with the original intent
of government policy and consistent with currently proposed measures. It would allow
existing coal plants to operate for peaking or during the winter months, for at least the next
10 years, thereby providing a backstop regulation in support of the carbon price support
mechanism. If plants seek to upgrade to operate at higher load factors into the 2020s it is
appropriate that this is in line with emissions reduction requirements that already apply to
investors in new coal plants, requiring the use of carbon capture and storage technology.
Operational and investment impacts
If the EPS is confirmed as proposed by the House of Lords, existing coal plant operators
would have two options:
1. Existing coal plant that upgrades to ‘opt-in’ to the IED would fall under the EPS, but
would still be able to run at around 40-45% load factor. This is in line with previous
government analyses that predicted higher carbon prices would reduce running hours.
2. Existing coal plant that decides to ‘opt-out’ and not upgrade would not fall under the
EPS, but would instead be limited to running 17,500 hours through until 2023. This plant
would likely operate mainly during winter to reduce costs and maximise earnings and
would thereby contribute to maintaining security of supply for the next 10 years.
Importantly, the investment case for new gas plant (and the use of existing mothballed
assets) centres on operators being confident that they will be able to secure significant load
factors during the first 5 to 10 years of plant operation. This investment case would best be
assisted by limiting the use of old coal plants as described above. The continued base load
operation of existing coal plant is currently the biggest barrier to investment in new gas
plant.
> 4 http://www.businessweek.com/news/2013-06-10/eu-should-move-beyond-carbon-market-to-shut-coal-
power-iea-says / http://www.iea.org/newsroomandevents/pressreleases/2013/june/name,38773,en.html
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International EPS developments
Emissions Performance Standards (EPS) have been successfully used worldwide for decades
to secure improvements in air quality by requiring reductions of pollutants from power
plants. More recently, the concept of EPS has been extended to address emissions of CO2.
EPS regulations for CO2 have been in place in California and other US states since 2006.5
Canada put in place a Federal EPS policy in 2012 that covers both new and existing power
plants.6 In June 2013, President Obama announced that the US EPA would bring forward
new source standards for power plants this year, to be followed by regulations on existing
plant during 2014.7 The World Bank and European Investment Bank now apply EPS
requirements in their assessment of financing for new power plants, while the European
Commission has recently consulted on policy options that could incentivise carbon capture
and storage (CCS), including via the use of EPS regulations. The UK’s proposed EPS could
therefore form part of a worldwide effort to reduce emissions of CO2 from fossil fuel power
plants, including via the accelerated deployment of CCS.
Questions and answers
Why is the EPS needed?
The government claims that the EPS is not needed as carbon pricing will provide a sufficient
means of limiting coal use over the coming decade. This view is not shared by the
International Energy Agency, which has recommended that European governments should
use non-price measures to ensure the prompt retirement of existing coal power stations.
The fact that existing coal plants are currently considering upgrades that would enable them
to operate through until the late 2020s demonstrates that the signal to investors of potential
future high carbon prices is not sufficient. This situation runs contrary to previous advice
from the Committee on Climate Change, which has repeatedly highlighted that there should
be no unabated coal generation in the UK from the early 2020s.
Even in the case that carbon prices do prove to be sufficient in future, the inclusion of
existing coal plants under the EPS now provides an appropriate backstop measure that
confirms the intention of policy and guards against further lock-in to high carbon electricity
generation assets. The inclusion of existing coal plants under the EPS will therefore send a
valuable signal of the UK’s commitment to pursue power sector decarbonisation, enabling
cost-effective investment in low-carbon technologies including a combination of unabated
gas and carbon capture and storage.
> 5 http://www.raponline.org%2Fdocs%2FRAP_ResearchBrief_Simpson_EPS_Updated_2010_08_12(2).pdf
6 http://www.globalccsinstitute.com/insights/authors/davidhanly/2012/12/04/emission-performance-standards-
old-option-new-incentive-ccs 7 http://www.whitehouse.gov/the-press-office/2013/06/25/fact-sheet-president-obama-s-climate-action-plan
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Will the inclusion of existing coal plants under the EPS require them to close in the next
few years? Will this impact on security of supply before 2020?
No. If a coal plant decides not to upgrade, then it would be able to run for a maximum of
17,500 hours out to the end of 2023 – a full decade from now. Even if operators chose to use
this allowance quickly by running at ~55% load factor, plants would still be operational until
2020. Given the introduction of the capacity mechanism, it is likely to be beneficial for plant
operators to phase availability of plant over the period to 2023.
What happens if a plant upgrades to meet pollution controls?
At present, any plant upgrading to meet the air pollution requirements of the IED would be
able to run at high load factors. Over time the government believes that this will be reduced
due to the increasing impact of carbon pricing. However the current combination of the EU
ETS and the UK’s Carbon Price Support are not sufficient to trigger fuel switching from coal
to gas. Under the EPS, a plant would still be able to upgrade to take advantage of greater
operational flexibility, however it would be limited to a load factor of around 40-45%. This
would position it in line with the emissions permitted for new coal plant under the EPS,
improving the business case for investment in new low-carbon generation assets.
Is this retrospective regulation?
No. Decisions are still to be taken as to whether coal plant operators will chose to opt in to
the Industrial Emissions Directive. An initial indication is required by 31/12/2013, but does
not need to be confirmed until 31/12/2015. Operators are currently waiting to see what
support will be offered under the capacity mechanism before confirming their intentions. It
is therefore clear that government decisions on the EPS and provision of financial support
are the key determinants for whether plants will seek to upgrade. One plant (Ratcliffe, E.ON)
has already invested to meet IED pollution control requirements. If necessary, the detailed
secondary regulations for the EPS could confirm whether this plant is excluded or included
under the EPS.
What about CCS?
It is unlikely that existing coal power stations will retrofit CCS given underlying plant
inefficiencies. However a number of plants are ideally located for the rapid deployment of
CCS in the early 2020s on either new units or alongside boiler refurbishment, assisted by the
development of CO2 transport infrastructure under the UK CCS Commercialisation
Programme:
> Drax is host to the White Rose Oxyfuel CCS project, which is participating in the
Commercialisation Programme. This will provide a CO2 transport and storage
infrastructure that can subsequently be utilised by additional units of CCS on the same
site.
> Eggborough and Ferrybridge sites have both been identified as potential candidates for
future deployment of CCS as part of a Yorkshire and Humber CCS network. Such a
network would also likely include the proposed new coal-fired CCS power station at Don
Valley.
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> Longannet already has a CO2 transport solution available, and both the plant location
and the CO2 pipeline have been identified as National Developments in the Scottish
Government’s National Planning Framework. A CO2 network in Scotland would also
include the proposed new CCS power station at Grangemouth, and could also
incorporate the existing Cockenzie site.
> An additional CCS project is proposed for Teesside, which would provide additional
opportunities for CO2 network development in the North East of England.
The deployment of CCS in the early 2020s on these sites is achievable as part of the UK’s CCS
strategy, and would provide a sustainable long-term future for power generation in these
locations. A proactive strategy would use the next 5 years to prepare firm plans for
investment via Contracts for Difference and associated infrastructure support, enabling the
construction of new CCS power stations at these locations by 2023.
What would happen if the UK doesn’t extend the EPS to include existing power stations?
The immediate impact would be to further incentivise investment in upgrades to enable
extended operation. This would negatively impact on the investment case for new gas plant,
and increase costs under the capacity mechanism. Beyond the policy framework, global
campaigns against coal power stations are likely to continue over the coming years. The UK
has already seen direct action opposition to new and existing coal-fired power stations.
There would therefore be an increased risk of direct action opposition in the event that
multiple coal plants seek to upgrade to extend operating lifetimes.
What international influence would this have?
Acting now to prevent lock-in to unabated operation from existing coal power plants will
provide a clear signal that the UK is acting domestically to limit the impacts of coal use, just
as it is restricting international funding for coal power stations elsewhere. The inclusion of
existing coal plants under the EPS would therefore send a valuable signal of support to
efforts underway in the USA and Canada to also address CO2 emissions from existing power
stations. It would also increase the pressure on EU member states to address emissions from
coal more proactively in their domestic climate policies. The review of the EU CCS directive
in 2014-15 will also provide an opportunity for re-consideration of whether an EU EPS would
be possible as a means of addressing emissions across the internal energy market.
About E3G
E3G is an independent, non-profit European organisation operating in the public interest to
accelerate the global transition to sustainable development. E3G builds cross-sectoral
coalitions to achieve carefully defined outcomes, chosen for their capacity to leverage
change. E3G works closely with like-minded partners in government, politics, business, civil
society, science, the media, public interest foundations and elsewhere.
For further information, please contact: Chris Littlecott, Senior Policy Advisor, E3G.
[email protected] | M: +44 (0)7920 461812 | T: +44 (0)207 593 2032
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Annex 1: Amendments introduced in the House of Lords
Now confirmed in the Energy Bill are amendments to the EPS introduced by the government
to provide additional flexibility for new CCS power stations during an initial 3-year
commissioning window. This addition is time-limited and provides greater clarity on the
required operation of CCS, in line with power sector decarbonisation objectives.
At report stage in the House of Lords, peers voted in support of an amendment that
incorporates existing coal plants into the EPS regime if they undertake pollution control
upgrades as a means of extending operating lifetimes. This provides improved consistency,
as the government already intended to include under the EPS any plant undertaking major
improvements (such as boiler upgrades).
Schedule 4 of the Energy Bill was amended by the House of Lords to read:
Application and modification of emissions limit duty
Application of duty: changes to main boilers
1 (1) Regulations under section 57(6)(b) may provide for the emissions limit duty to apply
(with or without modifications) in relation to fossil fuel plant in cases where—
(a) immediately before the day on which section 57(1) came into force, the
electricity generating station in question was the subject of a relevant consent,
and
(b) on or after that day—
(i) any main boiler of the generating station is replaced,
(ii) an additional main boiler is installed for the generating station, or
(iii) substantial pollution abatement equipment dealing with oxides of sulphur,
oxides of nitrogen, heavy metal emissions or particles is fitted to the generating
station.
The introduction of this amendment can therefore be seen to match the original intent of
the government to include existing plant under the EPS when undertaking technical
upgrades to extend operating life.
Upgrades to pollution control equipment to meet the IED have the same outcome of
extending operating life, as they would enable plant to operate beyond the 2023 end date
for opted-out plant. Additionally, such upgrades would enable plant to operate at much
higher load factors prior to that date than possible under the 17,500 hours limitation of the
IED.
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Annex 2: Status of coal-fired power plant in GB8
Coal-fired power plant opted out under LCPD provisions
Station Owner Capacity (MW) Status
Ironbridge EON 972 Converted to biomass but will
close by 2015
Kingsnorth EON 2000 Closed
Didcot RWE 1920 Closed
Tilbury RWE 1050 Converted to biomass and
recently decided not to re-
license so will close by 2015
Cockenzie Iberdrola 1200 Closed
Ferrybridge (units 1&2) SSE 980 Due to close March 2014
Total capacity 8122
Coal-fired power plant opted in under LCPD provisions
Station Owner Capacity (MW) Status
Eggborough Eggborough
Power Ltd
2000 Considering biomass conversion
– no apparent plans to opt-in to
IED
Uskmouth SSE 360 120MW closed, future of
remaining 240MW to be
decided by early 2014 but
unlikely to be opted in
Drax* Drax Power 3960 3 units to convert to biomass
and still to confirm future of
remaining 3 units
Cottam* EdF 1948 Yet to decide
West Burton* EdF 1924 Yet to decide
Ferrybridge (units
3&4)*
SSE 980 Yet to decide
Ratcliffe* EON 2000 Has already undertaken work to
comply with IED
Rugeley GdF 996 Considering biomass conversion
Aberthaw* RWE 1386 Yet to decide
Longannet* Iberdrola 2400 Yet to decide
Fiddlers Ferry* SSE 2000 Has received planning
permission for necessary works
Total capacity 19954
* Those stations most likely to consider opting in to the IED on the basis of public statements by the
owners
> 8 Source: The future of existing coal plant in GB and implications for security of supply and
affordability, Trilemma UK, October 2013. Note: There is also a small coal-fired power station in Northern Ireland that is expected to opt-out of
the IED
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Annex 3: Government arguments against extension of EPS
Quotes taken from Hansard report of Energy Bill debate, 4th December 2013
Government argument, as expressed by Michael
Fallon MP, Minister for Energy E3G comments
First, the Government do not consider that power to
be necessary. Secondly, the measure risks deterring
any investment in equipment needed to comply
with the directive, the consequences of which could
be detrimental to consumers.
The government claims that the
power is not considered necessary as
carbon pricing believed to be
sufficient – contrary to
recommendation of IEA. Yet
Government fears EPS could prevent
plant undertaking upgrades, which
would suggest that carbon pricing
won’t be sufficient.
Coal is being removed from the system due to a
number of factors, including the old age of some of
the plants, the impacts of environmental legislation,
the increasing penalty on high-carbon generation
applied under the carbon price floor, and increasing
levels of low-carbon generation as we introduce
more renewables.
Given all of these reasons, it seems
strange that the government would
seek to extend plant lifetimes rather
than clarifying the timetable for new
investment.
The coal fleet is old, having mainly been built in the
1960s and ’70s, with only one plant, Drax, under 40
years old. Most of these ageing power stations are
now expected to retire completely between now
and the mid-2020s. As I have explained, if a station
is not to face restrictions and/or closure under the
directive, it will need to invest in clean-up
equipment. That would require a multi-year
programme of investment in the order of several
hundred million pounds. Over time, with the carbon
price floor and a strengthening emissions trading
scheme, the economics of coal generation will
deteriorate further compared with gas.
Furthermore, as more low-carbon generation comes
on to the system through new nuclear and
renewables, it will result in higher-carbon coal
generation being increasingly displaced. The
combined effect is that the economic outlook for
coal generation is poor.
But this would still allow a plant to
upgrade now and run at potentially
higher load factors for another 12
years.
If the economic outlook for coal is
poor, then confirming a timeframe
for new investment gives greater
certainty for owners of existing plant
and potential investors in
replacement plant.
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Our analysis is consistent with that outlook and
shows that unabated coal generation will make up
just 7% of total generation by 2020 and 3% by 2025,
and probably 0% by 2030. There is no evidence at
the moment of a large number of operators
planning to upgrade their coal plants, but we should
not rule out the possibility that one or two might do
so.
Assumed that this analysis includes a
number of upgraded plants, but
details not been published.
Government approach appears to be
actively encouraging upgrades.
We have heard the argument that the amendment
would merely make available a tool for future
Governments to use, if necessary, to limit the
emissions from existing coal stations, but we believe
the very existence of such a power would create an
additional regulatory risk that could deter the small
number of our most efficient stations that might
otherwise choose to upgrade. As I have set out,
under the directive stations that do not upgrade will
be subject to limited hours and/or forced to close. If
the amendment were accepted, therefore, we
would risk more coal stations closing earlier than
might otherwise be the case.
Government would be able to define
when EPS would apply to give
forward clarity and reduce regulatory
risk.
This seemingly refers to some plants
closing by 2023 in line with IED
timetable, rather than 2025 as
claimed earlier due to carbon pricing
under government’s preferred
approach.
I have also considered the argument that the
amendment would provide greater certainty to
investors looking to build the new gas plant that we
all agree will be needed. However, the amendment
would do so in a way which could create risks for
our security of supply and increase costs to
consumers. We already face a significant investment
challenge with an estimated 16 GW of new gas
plant, and about 45 GW in total of all forms of
generating capacity, needed over the decade from
2015 to 2024. We are acting to facilitate that new
investment through other measures in the Bill,
notably with regard to the capacity market.
However, we cannot be 100% certain about exactly
when all that investment will be delivered. We need
a managed transition to a lower-carbon future, in
which our existing assets are managed prudently to
avoid unnecessary costs to consumers.
The government claims that it needs
to keep existing coal plant operating
as insurance policy against not
delivering new gas investment.
However the biggest barrier to new
gas investment is continued
operation of existing coal plant,
thereby risking the creation of a self-
fulfilling prophesy.
Analysis by CCC on achievability of
emissions reductions points to low-
cost benefits of using existing gas
generation assets rather than carbon
intensive coal plant.
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The Department has looked at a scenario in which
all our coal stations close by 2025, the results of
which show that average household electricity bills
would be about 3% to 4% higher—or about £22 to
£28 higher—in the 2020s. That would require more
gas plant to be built earlier to fill the gap—at
greater cost, ultimately, to consumers. It makes no
sense to accept an amendment that unnecessarily
creates further risks to our security of supply and
further increases costs to our consumers.
This scenario is not one that would
follow subsequent to the
introduction of the EPS. An existing
coal plant that upgrades and falls
under the EPS would be able to
operate at 40-45% load factor during
the 2020s.
If the business case for investment in
new gas is improved by limits on the
operation of existing coal plant the
costs of the capacity mechanism to
consumers may be lower.
In the end, as I said, this is a judgment. Is it right
now to accelerate the closure of coal and to force all
coal off the system by 2025? In my view, that will
add to the risks to security of supply and—I must
say this to my hon. Friends on the Liberal Democrat
Benches—will certainly add to the costs for our
constituents. We estimate that if coal disappears by
2025, there will be an increase in domestic bills of
about 3% to 4%, or about £22 to £28, and an
increase in non-domestic bills of between 4% and
6%. A large number of Members from all parties
attended the debate in Westminster Hall this
morning and complained about the costs being
imposed on energy-intensive industries, and we
estimate that their costs will increase by between
5% and 7%.
This statement is doubly incorrect, in
that it claims that it would force all
coal off the system by 2025.
Firstly, the EPS amendment would
not do this unless specified to include
a firm end date.
Secondly, it is the stated intent of the
government that carbon pricing
should itself force existing coal off
the system during the 2020s. The
minister referred to modelling that
suggests only 3% of electricity
generation would come from
unabated coal in 2025 and 0% by
2030. The difference in outcomes
between carbon pricing and use of
the EPS is thereby marginal – yet the
government seems to fear that an
EPS would be more certain in
delivering reductions in emissions.
This proposal will increase the risks to our security
of supply and add to the expense of our
constituents. I think that is too great a risk and too
high an additional expense and I urge the House to
reject the amendment.
These arguments have not been
supported by any published analysis
from DECC.