Agenda item

            (Mr. W. Francey, Director of Health and Environmental Services, attended in connection with this item.)

 

            The Director of Health and Environmental Services Committee submitted for the Committee’s consideration the undernoted report:

 

“Relevant Background Information

 

      Within Northern Ireland, the government Department with principal responsibility for energy generation is the Department of Enterprise, Trade and Investment (DETI). Commensurate with its renewable energy policies, DETI has established a range of generating targets including 12% of Northern Ireland electricity to be generated from indigenous renewable sources by 2012. DETI has indicated that this target can be met by Northern Ireland’s developing onshore wind sector but has recommended also that other forms of renewable energy should be encouraged to develop in parallel. Consequently, DETI has published a Bioenergy Action Plan for Northern Ireland covering the period 2009-2014 for consultation, which draws upon contributions from a range of government Departments. The Bioenergy Action Plan is also underpinned by findings and recommendations of an AEA Energy and Environment study into the current and future potential of bioenergy within Northern Ireland.

 

Key Issues

 

      DETI has indicated that the overall aim of the five-year action plan is to increase the deployment of bioenergy, with particular emphasis on heat and electricity, which will help to secure Northern Ireland’s energy supply, deliver carbon emission reductions, generate economic and environmental benefits and contribute to our renewable energy targets. Accordingly, the plan proposes four strategic objectives:-

 

·         to raise awareness and understanding of the benefits and opportunities of bioenergy.

 

·         to create a policy and regulatory framework to support bioenergy development

 

·         to encourage investment in the bioenergy supply chain, and

 

·         to continue to undertake research into bioenergy.

 

      Air Quality

 

      DETI’s recognition that biomass fuels can have a detrimental impact upon air quality and in particular, ambient concentrations of nitrogen dioxide (NO₂) and particulate matter (PM₁₀, PM_2.5) in urban locations is an important issue for Council. DETI has suggested that since much of Northern Ireland can be regarded as rural or semi-rural, this will not be a significant problem. Nonetheless, DETI has indicated that it will take account of DEFRA research, which shows that impacts of biomass on air quality can be reduced to a manageable level to avoid breaches of European and national air quality legislation. DETI has also indicated that in collaboration with DoENI, it may seek to amend the Clean Air Order to provide greater consistency between current air quality objectives and biomass combustion in order to move towards an approvals system, which removes the need for individual testing of boilers.

 

      It is considered that DETI comments regarding the potential impact of biomass installations do not adequately differentiate between the potential cumulative impact of numerous small-scale biomass installations and larger plants that may be subject to control under the Pollution Prevention and Control Regulations (Northern Ireland) 2003, and whose air quality emissions are consequently easier to control. It is suggested therefore, that larger and cleaner installations should represent the preferred approach to biomass energy in urban locations or where Air Quality Management Areas have been declared.

 

      In relation to Air Quality Management Areas, Part III of the Environment (Northern Ireland) Order 2002 places a statutory duty upon local authorities to assess periodically air quality within their districts against a series of national and European health-based standards. Where a local authority determines that an air quality standard is likely to be exceeded in the compliance year, then the authority must designate an Air Quality Management Area and develop an action plan in collaboration with other relevant authorities.

 

      In 2006, Belfast City Council designated four regions of the city as Air Quality Management Areas for a combination of NO₂ and PM₁₀, principally associated with road transport. The Council subsequently developed an Air Quality Action Plan in collaboration with the Department for Regional Development Roads Service and Translink. It is considered that an increase in particulate or nitrogen dioxide emissions from biomass installations could materially impact upon implementation of this Action Plan and the city’s ability to achieve the nitrogen dioxide and particulate matter air quality standards. Moreover, the wide scale deployment of biomass, as proposed via the DETI Bioenergy Action Plan, would have to be carefully managed within Belfast to avoid the need to declare further Air Quality Management Areas.

 

Resource Implications

 

      Financial

 

      N/A

 

      Human Resources

 

      N/A

 

      Asset and Other Implications

 

      N/A

 

Recommendations

 

      The Strategic Policy and Resources Committee is invited to endorse the attached consultation response in respect of the draft DETI Bioenergy Action Plan for Northern Ireland 2009 – 2014 and to recommend that it be submitted to the Department of Enterprise, Trade and Investment by 30^th October 2009. At the time of submission, DETI will be advised that comments are subject to Council ratification at its meeting of 2^nd November 2009.

 

Key to Abbreviations

 

DEFRA  -   Department for Environment, Food and Rural Affairs. 

DETI     -   Department of Enterprise, Trade and Investment.

DoENI   -   Department of Environment.

PM₁₀     -   particles with an aerodynamic diameter smaller than or equal to 10 micrometers.

PM_2.5     -   particles with an aerodynamic diameter smaller than or equal to 2.5 micrometers

 

Documents Attached

 

Appendix A  -   Belfast City Council response to the Department of Enterprise, Trade and Investment consultation on the Bioenergy Action Plan for Northern Ireland 2009 ? 2014.

 

Appendix A

 

Belfast City Council response to the Department of Enterprise, Trade and Investment consultation on the Bioenergy Action Plan

forNorthern Ireland 2009 - 2014.

 

      Having reviewed the draft Bioenergy Action Plan for Northern Ireland 2009 – 2014, Belfast Council submits the following comments in response.

 

Air Quality Considerations

 

      Strategic objective 2 (page 18) of the draft Bioenergy Action Plan states that there is an intention ‘to create a supportive and encouraging policy and regulatory framework within which the bioenergy sector can develop and thrive’.

 

      In addition, paragraph 16 of this section refers to air quality issues stating, ‘It is important to ensure that increased use of biofuels to generate energy does not have a detrimental impact on air quality.’ Belfast City Council would concur fully with this statement.

 

      In the same paragraph however, the text states ‘Given that much of Northern Ireland could be described as rural or semi–rural, it is not considered that this issue would be of a similar scale as potentially in other parts of the UK’. Belfast City Council considers this statement to be a generalisation and that the installation of biomass appliances in urban locations of Northern Ireland, of which Belfast would be the largest, should be carefully controlled.

 

      The Department for Environment, Food and Rural Affairs (Defra) has commissioned a UK-wide study of the potential air quality impacts of a major expansion of biomass heating. There are numerous ‘Key Messages’ from this research, which are pertinent to the development of a Bioenergy Action Plan for Northern Ireland. These are summarised as follows:-

 

·         To meet its 2020 renewable energy targets, the United Kingdom needs to increase substantially the amount of heat generated and biomass heat is one of the key technologies.

 

·         The potential conflicts between these goals and air quality can be avoided through the use of high quality low emission plant. The replacement of old coal and oil fired plant with high quality wood-fired plant, located off the gas grid and away from densely populated urban areas may actually benefit air quality.

 

·         In urban areas or where an Air Quality Management Area has been declared, Defra would expect biomass heat deployment to be less common and larger (and therefore cleaner) biomass plant to be more prevalent.

 

·         Encouraging the use of larger plant, for example in conjunction with the development of heat networks, will result in a system where air quality emissions are easier to control than from a larger number of small plant.

 

      Defra, whilst supportive of the need to employ biomass heating techniques, has raised concerns regarding the possibility of making air quality worse in certain areas. Indeed, Defra has accepted that implementation of the abovementioned ‘Key Messages’ will not be entirely straightforward.

 

Specific air quality issues of concern

 

      Emission levels

 

      In common with other combustion plant, the combustion of biomass can impact upon air quality in a variety of ways. Emission levels of pollutants such as particulate matter (PM₁₀ and PM_2.5), polyaromatic hydrocarbons (PAHs), carbon monoxide (CO) and sulphur dioxide (SO₂) depend upon the completeness of the combustion process. The temperature in conventional biomass combustion is generally insufficient to oxidise atmospheric nitrogen and therefore, nitrogen oxides (NO_x) are almost exclusively formed from the fuel. Accordingly, emission levels of nitrogen oxides are heavily dependent on the chemical composition of individual fuels, as are emissions of oxides of sulphur. Consequently, overall emissions are determined by the design of the combustion plant, the chemical and physical qualities of the fuel and the presence of emissions abatement equipment.

 

Approvals and consent

 

      In addition to meeting regulatory requirements, all but the smallest biomass installations will require planning consent. From an air quality management perspective, it is considered that a key component of the planning assessment process should involve an appropriate air quality impact assessment. Planning applications containing a biomass boiler should follow a risk-based approach and it is recommended that the assessment should consider:

 

·         Geography – what is the planned location of the biomass boiler, and could it potentially negatively affect any areas of poor air quality?

 

·         Fuel substitution/alternatives – will the biomass boiler be displacing a boiler running on a different fuel, and if so what fuel? If the development containing the boiler is on a new site, what other fuels might be available and what would be their comparative effect on air quality?

 

·         The likely emissions performance of the boiler

 

·         The type of biomass fuel that the boiler will be using

 

      If the assessment suggests that the biomass boiler may pose a risk to air quality, then detailed information about the biomass boiler will be required which may include the need for an atmospheric dispersion modelling study to quantify the spatial extent of any air quality impacts. Atmospheric dispersion modelling studies typically require significant technical air quality skills.

 

Boilers, fuel standards and certification

 

      The emissions performance of a biomass boiler depends substantially on its design and the nature of the fuel used. Most boilers are designed to use fuels of a specific type and quality, and deviation from this fuel type generally leads to poor combustion efficiency and increased emissions of ambient air pollutants.

 

      It is considered that current European Union and United Kingdom emission standards for biomass boilers are largely inadequate as tools for setting demanding air quality conditions, as they typically do not prescribe directly NO_x, PM₁₀ and PM_2.5 emission levels. Emission standards and eco labels have been developed by other European countries however, these are difficult to transpose to the United Kingdom owing to the wide range of approaches to testing and emissions measurement.

 

      Wood fuels are available in a variety of different forms and qualities and the performance of a biomass system is strongly dependent upon on the use of properly specified fuels. To aid the matching of biomass systems with the correct fuel supply, fuel standards have been introduced by several European countries. In the absence of United Kingdom specific standards, European standards are being adopted by some UK suppliers. In order to harmonise United Kingdom biomass fuels, it is recommended that UK specific standards should be developed.

 

Cumulative impacts

 

      Assessments of potential cumulative air quality impacts of multiple biomass installations will become increasingly important as the number of biomass installations increases over coming years. Whilst a single biomass boiler is unlikely to affect air quality outside its immediate vicinity, the cumulative impact of a number of biomass installations could potentially lead to localised air quality standards exceedences and also raise background pollutant levels. Steps should be taken therefore to ensure that biomass deployment is monitored and that screening assessments flag developing air quality issues. This is considered particularly important in urban locations where smaller biomass systems including stoves, room heaters and boilers may be installed in domestic premises. It is recommended therefore, that DETI considers working with local authority Building Control Services to monitor the prevalence of biomass appliances with a view to establishing installation trends.

 

Maintenance

 

      Biomass boilers, flue stacks and emission abatement equipment need regular maintenance to ensure that combustion efficiency is kept to a maximum and emissions are minimised. Many countries have already introduced a requirement for regular compulsory maintenance checks and it is recommended that similar provisions be considered for the Northern Ireland.”

 

            The Committee approved the draft response.