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Impact assessment of Proposal for a Directive on the limitation of emissions from medium combustion plants – National impact assessment compared to the European impact estimate

The paper shows underestimation of European estimate of the costs induced by the MCP Directive based on SimTool approach.

ABSTRACT: The December 2013 Medium Combustion Plants Directive (MCP Directive) proposal was evaluated by the national governments. In the Czech Republic, there are 6710 plants affected by this Directive, which is about 4.6% of the total of 143,000 relevant European plants.

The paper introduces our approach of policy impact assessment called SimTool. The costs estimated for the European Commission in the background study (AMEC, 2014) are assumed to reach EUR 5.9 million for the Czech Republic for the preferred scenario by the European Commission. Further presented national impact assessment estimates the induced annual costs of the proposal at EUR 61 million, which is about 10 times greater than the European impact assessment estimate.

As part of the national impact assessment, the different fuel categories had to be analyzed separately due to their specific features and different options for achieving the emission limit target values. During the impact assessment, a survey was made in order to determine the source operators’ preferences and responses to the potential adoption of the MCP Directive. Based on the analysis of data from the operators and consultations with experts about the different technologies, technical options for achievement of the proposed emission limits, including an estimate of the operating and investment costs, were proposed.

The paper concentrates on the Czech impact assessment approach and discusses the reasons of the discrepancy between the European impact assessment and the Czech version. We argue that the inaccuracies of the European impact assessments are given by usage of the general abatement cost curves in the models which do not reflect the reality sufficiently. This paper states an argument for the necessity to carry out analysis at the local level

Citation: Vojáček, O., Sobotka, L., Macháč, J., Žilka, M. (2018). Impact assessment of Proposal for a Directive on the limitation of emissions from medium combustion plants – National impact assessment compared to the European impact estimate. Renewable and Sustainable Energy Reviews (Vol. 82, pp. 1854-1862). https://doi.org/10.1016/j.rser.2017.06.119