SSE plc has selected the Limited Life Derogation (LLD) option under the Industrial Emissions Directive for its remaining capacity at its coal-fired power stations at Ferrybridge and Uskmouth.
Under this ‘opt-out’ derogation, the plants can run without fitting further abatement technology for a total of 17,500 hours or to the end of December 2023, whichever is the earlier.
The IED is due to come into effect from 1 Jan 2016 and imposes emission limits of SO2, NOx and particulates on all UK generation plant. In choosing how to respond to the directive plant operators have a number of options.
Defra has recently confirmed that generators selecting plant for the LLD will still have the opportunity to rescind this declaration and enter into the UK’s Transitional National Plan (TNP) or fully comply with the directive should they choose to do so before 1 Jan 2016.
All of SSE’s other qualifying UK thermal generation plant (including coal-fired Fiddlers Ferry and its gas plant) will remain in the draft TNP established by the UK Government in 2012, according to a 20 Dec company statement.
SSE said it believes that selecting some plant for the LLD, while maintaining other similar plant within the TNP, keeps open its options for it how operates this plant in future.
The plan is to monitor the development of the TNP over the next two years and, as key elements are finalised, will review whether it is appropriate to also move the plant at Ferrybridge and Uskmouth into the TNP.
The overriding goal is to maintain a diverse portfolio of assets that help keep the lights on, according to Paul Smith, SSE’s managing director, generation.
“The decisions we have taken surrounding the IED and at Peterhead have therefore been influenced by SSE’s well established principles covering how we operate and invest in our generation fleet over the long term, said Smith.
"We have kept open future options for our key generation plant while ensuring we meet the requirements of the IED, minimise risk and provide a degree of clarity and direction for the teams based at these sites.
"These decisions also enable SSE to maintain its diversity of technology and fuel types, respond flexibly to fluctuations in customer demand and ensure we have the capacity we require to meet the needs of our customers in a cost effective way," he added.
The IED is due to come into effect from 1 Jan 2016 for all of the UK’s existing large combustion generation plant. It imposes Emission Limit Values (ELVs) on emissions of SO2, NOx and particulates.
As an alternative to full compliance with the ELVs the Directive includes the options of: Transitional National Plan; Limited Life Derogation; and Limited Hours Derogation.
The EU's Member State Transitional National Plan provides a transition period between the implementation date of the IED of 1 Jan 2016 and the end of June 2020. Within this timeframe, plants can move towards full compliance with the IED, close, or limit generation to 1500hrs per year.
The UK TNP is still in development with a number of regulatory issues still to be finalised. The draft plan has recently been rejected by the European Commission and further points of clarification have been requested.
Once the plan is fully approved, it will then be consulted on and will need to be put into UK legislation. In addition, a number of other regulatory issues in relation to the operation of the TNP in the UK have still to be finalised.
Under the Limited Life Derogation ‘opt-out’ derogation, the plant - defined by the stack configuration - can run without fitting further abatement technology for 17,500 hours or to the end of Dec 2023, whichever is the earlier. LLD declarations had to be made before 1 Jan 2014.
Defra, however, has recently confirmed that plant opting for the LLD will still have the opportunity to rescind this declaration and enter into the TNP or fully comply with the Directive should it choose to do so before 1 Jan 2016.
Limited Hours Derogation allows plant to operate indefinitely under a 1500 hour per year - averaged over a rolling five years - derogation.
SSE opted to place all of its qualifying thermal generation plant within the UK TNP in May 2012.