Running out of time – the LCPD bites at last

Didicot A  on its last legs. Photo: Joe Dunckley CC BY-NC-SA

EU SO₂ emissions have been cut by 80 per cent and NOx emissions halved between 1990 and 2010. Things are going to get even better, thanks to the Large Combustion Plant Directive (LCPD), introduced in 1988.

In March 2013, the Didcot A power plant, near Oxford in southern England will be shut down. It used to emit 41,000 tons of SO₂ (equivalent to 128,000 tons of concentrated sulphuric acid), 16,000 tons of NOx and six million tons of CO₂. It was ranked 24th of the worst point sources of SO₂ among the then 25 members of the EU .

Didcot was commissioned in 1964, long before acid rain entered the political agenda, let alone climate change. It is now on its deathbed, as a result of the 1988 LCP directive.

The original LCPD targeted the “new” plants, those in operation from July 1987 or later. The “existing plants”, such as Didcot were only indirectly addressed. The governments were obliged to cut the national SO2 emissions from such existing plants by about 30 per cent by 1993, and about 65 per cent by 2003.

This forced many, but not all, plants to improve their act by retrofitting flue gas desulphurisation. Some could survive because other plants took measures, and by using low-sulphur coal.

The LCPD was amended in 2001. Now old plants such as Didcot A (from before 1987) had to either conform to roughly the same emission standards as the post-1987 plants, or “opt out”.

Didcot A opted out, together with 219 other power plants or other combustion plants, more or less Europe’s dirtiest. Most of them are in Eastern Europe and the UK, but also a quite a few in France, Spain and Portugal, according to European Commission reports .

The 220 plants, with a total thermal capacity of about 90 GW in operation in 2006, will be retired at the latest by the end of 2015.  90 GW corresponds to about 30 GW of electric power, if all the plants were power plants (which most of them are).

The opt-out plants were given a maximum of 20,000 hours of operation between 2008 and 2015. Those 20,000 hours could be used for a little more than two years of constant operation and then had to shut down. Alternatively, a plant could operate for fewer hours per year (for example to cover winter peaks) but more years.

There are about 3,300 large combustion plants, of which 220 chose to opt out.

Most of the opt-out plants use coal to generate power, including lignite and peat.

Many have used up all or almost all of their hours. By 2012, 52 of them had less than one year (8,760 hours) to go, some not a single hour. They are essentially out of service.

Sixty-six of them have operated for less than 1,000 hours and quite a few not even one hour. Most of those are unlikely to ever operate. They are a last-resource reserve, and also essentially out of service.

So what will come in their place?

Despite having over 25 years’ notice, there is an element of panic in some countries. This is because the shutdown of the coal power plants coincides with a crisis in nuclear power and new doubts about increased dependence on natural gas.

Germany has been planning to phase out nuclear since 1998, while also cutting CO₂ and other emissions. Renewables are gradually replacing both nuclear and coal. Germany has no opt-outs, but wind and solar are intermittent, and have to be balanced with cross-border trade or by load-following other power plants. Load-following means less money for the plant operator, in Germany or outside.

Belgium has two opt-outs. It plans to phase out two (smallish) nuclear power reactors by 2015.  According to some people this meant a risk of blackouts in Belgium. Last summer, however, two (larger) nuclear reactors were found to have thousands of defects in the core vessels, and are have since been shut down. It is not clear when, or even if, they can restart, but Belgium made it through a full winter with an acceptable capacity margin at all times. This margin will shrink somewhat when the opt-outs cannot be used.

The UK has a bigger problem. The policy has been to replace phased-out coal power with new coal power, nuclear power, wind power and gas power.

In the real world however, the UK is phasing out nuclear. It has shut down 29 reactors, two of them during 2012, and several more to follow before possible nuclear new-builds could add capacity, at the very earliest by 2019.

New coal is going nowhere. E.ON gave up on building two 800 MW coal power units at Kingsnorth, citing lack of an economic case.  Another factor, though, was the strong opposition for climate reasons. The project did not agree well with the strong UK climate commitment. A long-standing effort to reconcile coal with climate policy has been carbon capture and storage. Efforts to make coal clean with CCS have failed so far – despite government offers of at least a billion pounds, on top of similar EU offers.

Gas power provides the UK with more electricity than coal and nuclear combined, and is not used at full capacity. But gas is expensive, and many worry that still more gas will mean higher electricity bills.
In short, the equation is: less coal, less nuclear, not much more gas. Wind power contributes 20 TWh/year, which could  become 40 TWh by 2015.  Regulator Ofgem has warned of blackouts by 2015, largely because of shutdowns of opt-outs.

So can more renewables really meet demand?

They will have to. In the short term, the only games in town are renewables, efficiency and demand side. It is really the same story as in Germany, Belgium and France (with many opt-outs and a bleaker future for nuclear) … and almost everywhere else. Less “base-load” means a more variable supply.

The high prices argument is not relevant. The public has to pay for investments in new power and grid capacity, either as taxpayers or as consumers.

With somewhat higher prices, and much more variable prices, there will be strong incentives to shift some consumption from peak to off-peak hours, or even minutes and seconds. With various market mechanisms and gadgets it is much cheaper to adjust demand than to build new power lines and power stations.

This has always been the case, but demand-side management has usually lost out everywhere because of strong vested interests for more supply.

The crunch caused by the fallout of the LCP, among other things, could be a double blessing. The air will be cleaner and the energy system more sustainable.

Poland and Romania will have to shut a lot of plants, but both have surplus capacity and many power lines for cross-border trade. Both also have significant wind power programmes, and an overwhelming potential to save electricity. They have also overestimated power consumption in previous forecasts.

In 1988, when the LCPD was adopted, climate change was high on the agenda, but this is nowhere to be seen in the directive. It missed a good chance by giving much less stringent emission limit values for coal than for natural gas.

Natural gas power emits no SO₂, much less NOx, less than half as much CO₂ per kWh, and is outperformed only by efficiency improvements and renewables.

In this respect, and by allowing coal subsidies, the EU has been a force for preserving coal rather than doing something about carbon emissions, all at the expense of air quality.

Now, 25 years later, the directive will actually lead to less coal, less CO₂, more renewables and greater efficiency.

Fredrik Lundberg

1 Mark Barrett 2004 http://128.40.58.147/markbarrett/Environment/LPS/APC17web.PDF p 31
2 http://ec.europa.eu/environment/air/pollutants/stationary/lcp/implementation.htm
3 IEA Medium term renewable energy market report 2012

Table: Opt-out plants as of 1 January 2012