Habitats and ammonia Rick Gould Ellie Stubbs and Judith Ford Outline Background Emissions sources of ammonia and pattern of emissions The installations that we regulate under the IED How we assess permit applications ID: 1025657
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1. How the Environment Agency assesses permit applicationsHabitats and ammonia Rick Gould, Ellie Stubbs and Judith Ford
2. OutlineBackgroundEmissions sources of ammonia and pattern of emissionsThe installations that we regulate under the IEDHow we assess permit applications Detailed modelling and assessmentThe models used – strengths and weaknessesModel validationMeasured versus modelled resultsSources of uncertaintyCurrent challenges Case law, thresholds, headroom (or capacity)2
3. 2019 onwards - The Clean Air Strategy3Source: NAEI
4. Ammonia, its sources, proportions and impact assessment4
5. Sources of ammonia5
6. Ammonia emissions by sectors6Industrial Emissions Directive – larger pig and poultry farms only – place for 40,000+ birds, 2000 ‘production pigs’ over 30kg and/or 750 sows.
7. Industrial emissions - apply BAT7Smaller energy generators:More of them, e.g. biomass boilers, MCPD installationsNOx control using urea injection – risk of ammonia emissions
8. The assessment process8
9. 9The process of assessment9Installation type, size and emissions factors; habitat proximityImpactAssessmentWe audit all modelling reports submitted with permit applications. The AQMAU audit a selection, i.e. those that need extra scrutiny. We have a risk-based process for selecting which applications go to AQMAU and those which are review by NPSCompare with critical levelsCompare with critical loadsMassemissionsScreeningGroundLevelConcentrations, CnEstimateDeposition(Cn x v x t x area)Dispersion modelling
10. 10NO2, NH3Source-pathway-receptorNOxNH3NO2NH3
11. Source-pathway-receptor11
12. Dispersion models12
13. Take into account background13Source: CEH
14. Golden rules of modelling14
15. 15Screening modelsSHSSSSSAST and SCAIL Ag (in conservative mode) set up the wind to be always blowing towards the habitat, all of the time.
16. Strengths and limitations of models16
17. Model validation17Source: Sniffer ER26 - Final Report - March / 2014
18. 18Model validationSource: Sniffer ER26 - Final Report - March / 2014
19. Lessons from validation exercisesThe model output is only as good as the data fed into the modelCaution – when extending the validated rangeBiggest source of uncertainty – the emissions factors, especially for intensive farmingEmissions factors for single-point sources are relatively easy to determineEmissions from intensive farms have many variables that are often difficult to measure19
20. Emissions factors for single-point sources20Reference monitoring using accredited test laboratories using certified equipment and validated EN standardsContinuous monitoring with certified instruments calibrated and verified
21. Emissions factors for diffuse sources21Source: Inventory of Ammonia Emissions from UK Agriculture, 2017, for DEFRA, by Misselbrook & Gilhespy
22. Current challenges22
23. Current challenges23
24. The Wealden Catch-2224Existing roadPlanned roadProtected habitat
25. 25WealdenIndividual sources are additivePoses a ‘Catch 22’ for screeningDefaults towards in combination assessmentsThresholds permissible if scientifically valid
26. ‘N headroom’ – Dutch Nitrogen Case26?N Headroom
27. 27The Dutch Nitrogen CaseReduce N inputs to habitats with unfavourable conservation status (above critical loads, evidence of this)Prevent further inputs of nitrogen, as these present difficultiesEven if evidence suggests no further damage, do extra inputs impede recovery?Avoid supposition of future headroomLeads towards nitrogen neutrality?Conflicts with NECR210?
28. So what are we doing and considering?28
29. Challenges29
30. Assessment and thresholds30In common amongst regulatory bodies in the UKScreening followed by detailed modelling and assessmentThresholdsReliance on APISActivity and modelling-centric assessmentsEmphasis on critical loads, application of NECR210DifferencesWidely varying thresholds0.1% to 100% thresholds across all types of habitat1%/8% to 4%/20% for European sites
31. 31Science underpinning 1µg/m3 / 3µg/m3 critical levels
32. 32Latest science for monitoringPaper on the validation evidence for a new EN standard for NH3 measurements
33. 33APIS and in combination assessmentsFor in-combination assessments, only new activities since 2017
34. Thresholds - optionsNeed to have thresholds backed-up by scientific evidenceWould we detect NH3/NO2 if the installation were permitted?Cement the link between critical loads and levelsCritical loads developed as long-term risk measures and for strategic objectivesCritical levels have a legal precedent - NO2 and SO2 in the 2008 Air Quality DirectiveConcentrations are easier to measure than depositionAlignment with other regulatory bodies?e.g. the 8% average risk-threshold derived from NECR210?e.g. 0.1% as a de minimis – because it is statistically close to zero?34
35. 35The origin of the 8% additional loadDecades of research – incremental increases of N resulting in no further loss of speciesDifferent values as a percentage of critical load, depending on habitat type8% is an average increment
36. The need for a strategic approach36
37. 37Ammonia headroom
38. Agricultural emissions by sub-sector38Pigs and poultry farms reported to emit less than ¼ of ammonia emissions from livestock. EA regulates less than ¼ of these, although these are the largest intensive farms
39. Agricultural emissions by activity39
40. 40Local headroom, and clusters in combinationSource: NRW
41. Strategic approachProposals in the Clean Air Strategy 2019Intensive beef and dairy farming to be brought into permittingRequirements for application of manure/slurry – precision farmingSpecifications for chemical fertilisers an optionNeed to consider sub-IED intensive farms, with a potentially significant impact?Most broiler intensive farms fall under the IEDMost egg-layer intensive farms are not under the IEDFood-strategy and socio-economic factorsWe all have to eat41
42. SummaryWe need to reduce national emissions further to meet legally-binding targetsWe need to reduce impacts locally in a cost-effective and efficient mannerBenefit in revisiting and align thresholds amongst regulatory bodiesWe will not reduce national NH3 emissions by focusing all attention on a few individual sectorsStrategic, habitat-centric approach could achieve thisFollow Dutch and Danish examples of how to make this work42