Information material. and policy recommendations. EU-UltraLowDust. D7.6: Final report

Transcription

1 Information material and policy recommendations D7.6: Final report

2 Final Information Material and Policy Recommendations (D7.6) Authors Antoine Durand Thomas Götz Johannes Thema Florian Dittus Mandy Hübschmann With support from Prof. Dr. Wolfgang Irrek Wuppertal, March 2014 Project Project Co-Ordinator BIOS Bioenergiesysteme GmbH (Graz, AT) Scientific Partners European Institute for Energy Research, EIFER (Karlsruhe, DE) Graz University of Technology, TUG (Graz, AT) Technologie- und Förderzentrum, TFZ (Straubing, DE) Wuppertal Institute for Climate, Environment, Energy (Wuppertal, DE) Industrial Partners RufTec (Obing, DE) Supra (Obernai, FR) Windhager Zentralheizung Technik GmbH (Seekirchen, AT) 1

3 Table of contents List of tables... 4 List of figures... 6 Abbreviations Introduction Current situation and technical challenges Relevance of the market for biomass solid fuel small combustion appliances Emissions in the EU-27 related to small scale solid biomass heating systems How aimed at tackling the emission issues Options for European policy-making Product standards and emission measurement Product standards Solid fuel local room heaters (Direct heaters): EN and pren Solid fuel boilers (Indirect heaters): EN Electrostatic precipitators (ESP) Measurement methods Product test standard emissions and real-life emissions Technologies Product categories covered by the project Standard technologies on the market (Base Case) Current Best Available Technologies (BAT) UltraLowDust technologies (ULD) UleWIN boiler technology developed by Windhager APS stove technology developed by SUPRA ESP technology developed by RUFTEC Summary of the UltraLowDust technologies Technical TSP reduction potentials Scenarios Wood pellet boilers Wood chip boilers Wood log boilers Wood log stoves Conclusion Policies in Europe Policies and instruments implemented on EU-level Forthcoming policies and instruments on EU-level EU policies on air quality EU policies for new SCI EU Ecodesign and mandatory Energy Labelling Voluntary EU Ecolabel and Green Public Procurement (GPP) National policies and instruments in the EU Member States Mandatory regulations Regulation for new SCI Regulation for existing SCI

4 Voluntary agreements Analysis of the current policy landscape in the EU Policy options and recommendations Why further policies are required Policy package for new SCI General policy package approach Two steps of improvement Step 1: Improving current product information MEPS and ELVs EU Energy Labelling (Revision) EU Ecolabelling Revision of current product standards Financial incentives Promotion and marketing activities by manufacturers and installers Overview Step 2: Addressing Real Life Emissions Revision of product and test standards Indirect heaters (boilers) Direct heaters (local room heaters) Update of the specific policy package for new SCI Overview Policy package for existing SCI General policy package approach Regulation: Minimum performance requirements for SCI Regulation: Fuel quality Information, education, training, networking and promotion Financial incentives Summary and Outlook References ANNEX I: Part load performance of the demonstrated technologies ANNEX II: Requirements in product standards and regulations ANNEX III: Information requirements for Lot 15 and Lot ANNEX IV: On-site measurement methods of the 1.BImSchV ANNEX V: Overview of national regulations in the EU

5 List of tables Table 1: Overview of the emission test methods Table 2: Main figures of the Base Case technologies Table 3: Main figures of the Best Available Technology Table 4: Main figures of boilers with UleWIN-technology Table 5: UleWIN-technology compared with BC and BAT boilers Table 6: Main figures of the APS stove Table 7: APS-technology compared with BC and BAT wood log stoves (nominal load) Table 8: Main figures of the demonstrated ESP Table 9: Ruftec ESP compared with BAT ESP-technology Table 10: Main figures of the ULD technologies Table 11: TSP emission reduction potential according to the respective scenarios Table 12: Cumulated TSP emission saving potentials Table 13: EU directives and conventions related to emissions of solid fuel heaters Table 14: EU directives generically related to solid fuel heaters Table 15: Proposed MEPS and ELVs for solid fuel boilers Table 16: Proposed MEPS and ELVs for solid fuel local room heaters Table 17: Proposed EU-Ecolabel MEPS and ELVs for solid fuel boilers Table 18: German ELVs and MEPS for direct heaters (type-testing based) Table 19: German ELVs for indirect heaters (boilers) Table 20: ULD technologies compared to the Ecodesign proposals Table 21: Proposal for new EN Classes Table 22: Main figures of UleWIN boilers at part load (30 % of nominal load) Table 23: EN 303-5:2012 Performance classes for indirect heaters (boilers) Table 24: German requirements for on-site measurement of indirect heaters (boilers) Table 25: German ELVs and MEPS for direct heaters (type-testing) Table 26: Mandatory Ecodesign information requirements for indirect heaters Table 27: Mandatory Energy Labelling information requirements for indirect heaters Table 28: Mandatory Ecodesign information requirements for direct heaters Table 29: Mandatory Energy Labelling information requirements for direct heaters

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7 List of figures Figure 1: Scheme of the strategic approach Figure 2: Schematic drawing of the SUPRA APS stove technology Figure 3: Schematic drawing of the ESP Figure 4: TSP emissions and stock volume (wood pellet boilers in EU-27) Figure 5: TSP emissions and stock volume (wood chip boilers in EU-27) Figure 6: TSP emissions and stock volume (wood log boilers in EU-27) Figure 7: TSP emissions and stock volume (wood log stoves in EU-27) Figure 8: Total TSP emissions and stock volume in EU-27 (scenarios for the market) Figure 9: Total TSP emissions and stock volume in EU-27 (incl. scenarios for the stock). 37 Figure 10: Cumulated TSP emission saving potential ULD_replace vs. ULD scenario Figure 11: Mandatory Energy Label for solid fuel boilers (Draft) Figure 12: Mandatory Energy Label for local room heaters (Draft) Figure 13: EU Ecolabel and GPP label Figure 14: TSP ELVs in EU countries for direct heaters (mg/mj) Figure 15: TSP ELVs in EU countries for indirect heaters (mg/mj) Figure 16: TSP labelling requirements in EU countries for direct heaters (mg/mj) Figure 17: TSP labelling requirements in EU countries for indirect heaters (mg/mj) Figure 18: Overview of European TSP regulation and labelling landscape Figure 19: Policy package for market transformation Figure 20: Current status of the policy package for new biomass solid fuel SCI Figure 21: Two-step approach for new solid biomass SCI Figure 22: Step 1 of the proposed policy package for new solid biomass SCI Figure 23: 8-hour boiler load cycle test sequence Figure 24: TSP emissions based on type testing compared to the 8-hour load cycle test.. 66 Figure 25: Step 2 of the proposed policy package for new solid biomass SCI Figure 26: Policy package for existing solid biomass SCI Figure 27: Low emission operation manual for chimney stove users Figure 28: Financial incentives as Pull mechanism Figure 29: Context of the policy packages for SCI Figure 30: CO ELVs in EU countries for direct heaters (mg/mj) Figure 31: CO ELVs in EU countries for indirect heaters (mg/mj) Figure 32: OGC ELVs in EU countries for direct heaters (mg/mj) Figure 33: OGC ELVs in EU countries for indirect heaters (mg/mj) Figure 34: NO x ELVs in EU countries for direct heaters (mg/mj) Figure 35: NO x ELVs in EU countries for indirect heaters (mg/mj) Figure 36: MEPS in EU countries for direct heaters (%), NCV based

8 Figure 37: MEPS in EU countries for indirect heaters (%), NCV based Figure 38: Labelling MEPS in EU countries for direct heaters (%), NCV based Figure 39: Labelling MEPS in EU countries for indirect heaters (%), NCV based

9 Abbreviations APS Active Power System Stove technology developed by Supra within the EU- UltraLowDust project ATEX ATmosphère EXplosive EU Directive on equipment and protective systems intended for use in potentially explosive atmospheres BAT Best Available Technology Most advanced technology currently available on the market BAU Business As Usual Refers to a scenario assuming the continuation of current policies without further modifications BC Base Case Typical standard/average technologies currently on the market BImSchV Bundes- ImmissionsSchutzVerordnung Ordinance on Small Firing Installations (German emission regulation) BNAT Best Not yet Available Technology Technologies currently being developed and to be available on the market in the future CE European Conformity Label to be applied to products according to EU directives CO Carbon monoxide CO 2 Carbon dioxide DD Down draft Down draft gasifying boilers EC The European Commission EFA European Fireplace Association Association of European heater manufacturers ELV Emission Limit Value Maximum emission level allowed by a regulation or labelling scheme EN European Norm EPBD Energy Performance of Buildings Directive See Chapter 6.1, Policies and instruments implemented on EU-level (2010/31/EU) ESP Electrostatic precipitator Electric PM abatement device (e.g. as tested and improved within the project) EU European Union EU-ULD project GHG Greenhouse Gas GPP Green Public Procurement MEErP Methodology for the Ecodesign of Energy-related Products MEPS Minimum Energy Performance Standard MS Member State Member State of the European Union Nm 3 Standard cubic meter Unit of volume for gases in standardised conditions NO x Nitrogen oxide O 2 Oxygen OGC Organic Gaseous Compounds PAH Polycyclic Aromatic Hydrocarbons PIC Products of incomplete Unburned gaseous compounds like CO, OGC, PAHs combustion PM Particulate Matter Dust particles. When referring to particles with a certain size, the size is given as follow: < 10 μm = PM 10 SCI Small-scale Combustion Installations TSP Total Suspended Particles Refers to the total amount of all PM particles measured in the flue gas ( dust ) ULD UltraLowDust 8

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11 1. Introduction The European Commission (EC) has declared 2013 as the Year of the Air in order to draw attention to health and environmental issues related to air pollution in Europe and the necessity to further improve air quality. The EU objective is "to achieve levels of air quality that do not result in unacceptable impacts on, and risks to, human health and the environment". 1 For this purpose, in December 2013 the European Commission adopted a new Clean Air Policy Package to improve air quality across Europe. Additionally, based on the EU Ecodesign and Energy Labelling Directives, a legislative process at the European level has been initiated to regulate the market of new small-scale solid fuel combustion installations (SCI) and to promote Best Available Technologies (BAT). The project aimed at the demonstration of Best Not yet Available Technologies (BNAT) for the next generation of biomass solid fuel small-scale combustion installations and the respective emission reduction potential. In this context, there are also still several issues to be clarified on EU-level. The comparability of emission measurements throughout Europe remains challenging, because measurement methods are not always harmonised. Furthermore, emissions measured according to product standards differ significantly from real-life emissions, due to many factors like user behaviour. At the same time, many countries in Europe have already implemented different policies such as emission limits, efficiency requirements, labelling schemes or financial incentives for new and existing SCI. Within these policies, there exists a large spectrum from very strict regulations to no binding regulation at all. In order to discuss these issues together with the EU-ULD results from EU and national perspectives as well as to develop strategies towards an effective reduction of emissions from biomass solid fuel combustion, one of the key steps of the project was to involve around 15 international experts from the major European markets as a Mirror Group. For this purpose, two workshop meetings of the Mirror Group took place in Brussels on 28th November 2012 and on 3rd December The members of the Mirror Group were representatives of selected EU or national authorities as well as experts of standardisation bodies and test laboratories. During the second workshop of the EU- UltraLowDust project, policy options and recommendations for policy packages (addressing new and existing SCI) with the aim to reduce emissions in Europe and to promote innovative technologies beyond BAT level have been discussed. Based on the comprehensive final results of the EU-ULD project, the Final overall environmental and socio-economic Impact Assessment (D5.6) and the inputs of the Mirror Group, the Information material and policy recommendations 2 provide a comprehensive overview for emission reduction measures in the SCI sector in Europe. 1 2 European Commission (2005) Please note: Due to the still on-going Ecodesign process at the time of the finalisation of the Project and this document, as well as the level of the proposed Ecodesign performance requirements, it is too early to propose further "recommendations regarding future emission limits" (as defined in the original project proposal). Regarding the possible future evolution of performance criteria for small-scale solid fuel combustion installations (SCI), please see also Chapter («Step 2»). 10

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13 2. Current situation and technical challenges 2.1. Relevance of the market for biomass solid fuel small combustion appliances Small-scale residential combustion of solid biomass has traditionally been used for space heating and domestic hot water production. Today, also after the introduction of several other heating technologies such as gas or oil, biomass solid fuel heating still holds a large market share and is also intended to be scaled up for taking the lead in a future renewable energy heating strategy. In Austria, for example, about 40 % of solid biomass combustion is related to the residential heating sector. In France, this share amounts to about 80 %, in Germany to about 60 % and the EU average in 2007 amounted to almost 40 % (AEBIOM, 2010). With the goal of providing 20 % of primary energy from renewable sources by 2020, the EC Directive On the promotion of the use of energy from renewable sources (2009/28/EC) expects residential solid biomass combustion to increase by 100 % compared to the reference year Emissions in the EU-27 related to small scale solid biomass heating systems As the current solid biomass combustion in the EU is already significant and a further expansion is planned, it is also important to take related harmful emissions into account. Especially Particulate Matter (PM) emissions have been identified as hazardous to health and therefore, in the EU Directive 2008/50/EC 3, a daily mean limit value of 50 μg/m 3 PM 10 is defined for the protection of human health, which shall not be exceeded more than 35 times per calendar year. However, even the most recent measurements show that this limit is regularly exceeded in many areas all over Europe. Next to transport, residential solid fuel combustion has been identified as one of the main sources for this ambient air pollution regarding PM, especially originating from old boilers and stoves. Regarding biomass solid fuels, wood pellet boiler technologies currently show the lowest emissions of all residential combustion systems and concerning CO (Carbon monoxide) and OGC (Organic Gaseous Compounds), they are already close to the low emission levels of oil and natural gas heating boilers. However, their PM emissions are still more than a factor 10 higher. For modern logwood boilers the figures are similar. In contrast, even state-of-the-art 4 logwood stoves still emit significantly higher amounts of CO and OGC (up to a factor of 100 compared with modern pellet boilers) and also the PM emissions are by a factor of 5 higher than the ones of pellet boilers. Another important aspect regarding emissions from residential biomass solid fuel combustion is the large existing stock of appliances, consisting of primarily old stoves and logwood boilers. In Austria, for example, this category represents about 85 % of the solid biomass based residential heating systems, a situation typical also for most other European countries. Mainly due to non-optimised combustion technologies, such old boilers emit by a factor of 100 to 150 higher amounts of PM compared to oil and natural gas boilers. These PM emissions consist predominantly of carbonaceous particles (organic carbon and soot particles), which originate from incomplete combustion. Statistics from Austria for instance have shown that in 2005 old wood stoves and boilers amounted to 15 % of the overall single house heating systems but emitted more than 85 % of the overall PM emissions of the entire Austrian residential heating sector. 3 4 DIRECTIVE 2008/50/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 21 May 2008 on ambient air quality and cleaner air for Europe. Also called Best Available Technologies (BAT). 12

14 Negative external effects of PM emissions have been evaluated in various frameworks. The Clean Air for Europe (CAFE) 5 Programme of the European Commission estimated that in the year 2000, mainly due to long-term health effects of PM 2.5, there were annually nearly 350,000 premature deaths due to cardiovascular and respiratory diseases as well as cancer among the 450 million population of the EU-25 Member States. In total, annual economic losses due to the health damage in 2000 were estimated up to 781 billion Euros (European Commission 2005). The public discussion regarding emissions and negative publicity have already initiated attempts for decreasing emission limits for residential biomass solid fuel heating systems in the near future (e.g. 1.BImSchV 6 in Germany), motivating the industry to develop new low emission technologies for small-scale solid biomass combustion in order to remain competitive or to keep market access. The main focus is the reduction of unburned gaseous compounds like CO, OGC and Polycyclic Aromatic Hydrocarbons (also termed as Products of Incomplete Combustion or PIC ) as well as PM in order to reach low emission levels for automated boiler systems similar to those of modern systems using liquid or gaseous fossil fuels. Old solid biomass boilers and stoves can be retrofitted with emission abatement systems and may thus also strongly contribute to emission reduction over their remaining lifetime How aimed at tackling the emission issues The project demonstrated and analysed three promising technologies for residential biomass combustion. A new ultra-low emission boiler technology for pellet and woodchip combustion (UleWIN technology), operating at almost zero detectable Total Suspended Particle (TSP), OGC and CO emissions as well as a new stove technology based on optimised air staging and an automated control system to reduce TSP, CO and OGC emissions (APS technology) have been developed and compared with contemporary appliances. Additionally, a new electrostatic precipitator system (ESP) has been demonstrated as retrofit abatement technology for TSP emission reduction. These three technologies (UleWIN, APS, ESP) are intended to define a new state-of-the-art for ultra-low emission solid biomass combustion. The project also aimed to develop recommendations for future policies under consideration of the results achieved by the ULD technologies, which were then discussed with national and EU authorities active in legislation making. To reach these aims, a consortium of partners from three EU-countries had been formed. It consisted of the manufacturers of the analysed key technologies, research institutions which supported the industrial partners with their expertise in solid biomass combustion, one partner active in the field of international networking and policy making as well as an internationally recognised engineering company, experienced in market studies and technology assessments, as project coordinator See: Ordinance on small and medium size combustion installations Erste Verordnung zur Durchführung des Bundes-Immissionsschutzgesetzes (1.BImSchV) of January 26th, See: 13

15 2.4. Options for European policy-making As outlined above, there are large potentials to increase small-scale renewable biomass solid fuel combustion in the European market for greenhouse gas (GHG) emission reduction purposes and to reduce also TSP, OGC, CO and NO x emissions at the same time through the market diffusion of significantly improved combustion systems such as the new technologies demonstrated in the project. In order to realise these potentials and to accelerate the market transformation, SCI specific policy instruments are needed. This document presents the product standards and emission measurement methods, which are relevant for the analysed technologies and as important basis for respective regulatory measures (Chapter 3). Chapter 4 gives an overview of the technologies as demonstrated within the project. Additionally, the technical emission reduction potentials in Europe are estimated for different scenarios by means of a stock modelling approach (Chapter 5). The policy section (Chapter 6) provides an overview over the range of regulations already implemented or forthcoming on EU-level, with special focus on the current status of the European air quality policy as well as the Ecodesign and Energy Labelling process for solid fuel small combustion installations in particular. 8 The national regulations in the EU Member States are presented from a core of countries with strict ELVs to many countries without any regulations. Additionally, national and international labelling schemes are compared. Finally, Chapter 7 presents comprehensively the options and recommendations for future policy-making, both on EU and national level. 8 See Lot15 Preparatory Study covering direct and indirect solid fuel heaters. Please note that direct biomass heaters might be regulated within Lot20 (local room heating products). room_heating products 14

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17 3. Product standards and emission measurement 3.1. Product standards Concerning solid fuel heaters, different European (EN) standards 9 have been adopted. The standards include specifications for various product features such as technical design, safety issues as well as test conditions and classifications for emissions or efficiencies. The goal of the standards is to provide reliable and harmonized technical information as basis for the European Single Market. The following section presents the most important EN standards for direct heaters (e.g. stoves) as well as indirect heaters (boilers) Solid fuel local room heaters (Direct heaters): EN and pren The EN covers room heaters fired by solid fuels. Regarding the emissions of TSP, all measurement methods described in Annex A of the Technical Specification CEN/TS (Residential solid fuel burning appliances - Emission test methods), including the dilution tunnel method, can be used. Therefore, condensable organic compounds and the resulting additional particulate matter may be included. Consequently, results obtained from the different TSP test methods are generally not comparable. Due to the limited ability of the appliances in the scope of EN to modulate the heat output, the nominal heat output (the declared heat output of an appliance achieved under defined test conditions when burning the specified test fuel in accordance with the standard) is in the focus of the TSP measurement methods. Regarding other operating conditions, the high emission cold start ignition phase is not covered. Depending on the used measurement method, the emissions of the warm start phase (basic fire bed has already been established) and refill operations may be included. EN will be superseded by the forthcoming (pr)en for residential solid fuel burning appliances, applicable for room heaters, inset appliances including open fires, cookers and independent boilers with a nominal heat output up to 50 kw. Each of the four product groups is described in detail as sub-part within Part 2 of pren At a later stage it is possible to add further sub-parts in order to cover other residential solid fuel burning appliances such as pellet or slow heat release stoves. Part 1 of pren (General requirements and test methods) includes CO, NO x, OGC/total hydrocarbons and particulate matter emission test methods. Thereby, the pren mentions the possibility to estimate roughly TSP emissions, which would have been measured according to the dilution tunnel method, through the combination of the gravimetric heated filter particle measurement method with OGC measurements. As its predecessor, pren does not contain any performance classes or limit values for emissions Solid fuel boilers (Indirect heaters): EN The EN 303-5:2012 for manually and automatically stoked solid fuel heating boilers sets emission limits to achieve boiler efficiency and emission classes 3, 4 or 5. The requirements of the claimed performance class have to be fulfilled when operating at nominal heat output or, in the case of boilers with heat output range, when operating at nominal heat output and minimum heat output. Besides the dust content (TSP), the emissions of CO 2 or O 2, CO, OGC (and NO x where relevant) have to be measured in the flue gas. TSP emissions shall be determined using a filter sampling method according to CEN/TS and EN in combination with Annex A of EN 303-5, or using a gravimetric or electrostatic sampling method according to 9 A standard (French: norme, German: Norm) is a publication that provides rules, guidelines or characteristics for activities or their results, for common and repeated use. 16

18 EN Annex C. Other national methods or practices meeting the error limit requirements given in EN may be also used. Regarding dust emissions, the class limits 10 of the EN are based on the experiences of the gravimetric filter method and do not include condensable organic compounds, which may form additional particulate matter when the flue gas is mixed with ambient air. The TSP values are therefore not comparable with values measured by other methods, and especially not with the dilution tunnel method. Boilers shall be brought to operating temperature and predominantly stable operating conditions before the start of any measurements. Therefore, the cold start phase of boilers and its emissions are not included in the EN requirements. The subsequent refill operation or stoking intervals during the analysed period are covered by the test results. Besides nominal load operation, minimum heat output is also covered (if applicable for the tested boiler). Thereby, minimum heat output can be achieved either by power output modulation or intermittent onoff mode operation Electrostatic precipitators (ESP) Up to now, there is no harmonized EN standard for the measurement of TSP precipitation efficiency available. Other respective future standards, like the German DIN 33999, are still under preparation. Due to this lack of standardisation, it is neither possible to compare directly the precipitation efficiency figures mentioned by different ESP manufacturers nor to validate universally the real performance of a tested system Measurement methods The product standards EN as well as EN and pren refer to emission test methods, which are listed in Table 1. Thereby, CEN/TS includes the technical specifications for particle emission test methods for residential solid fuel burning appliances. It defines testing conditions of the Austrian/German, the Norwegian (with dilution tunnel) and the UK particle test methods as well as the respective dust measuring equipment. pren also refers to CEN/TS 15883, but includes also own specifications for emission test methods. Basically, for NO x, CO and OGC emissions, harmonized test methods exist and comparable results can be achieved. However, TSP values from solid fuel SCI obtained by the common measurement methods differ significantly. For example, the Norwegian method also includes additional particulate matter from condensation of gaseous organic compounds in the dilution tunnel. This leads to higher measured TSP emission values compared to the Austrian/German (gravimetric, heated filter, undiluted) method. In order to deal with this issue, the most recent standard pren (Annex G) mentions a combination of the gravimetric heated filter method and OGC measurements to allow a calculation of total particulate emissions and the comparison with the results obtained by the dilution tunnel method. Furthermore, the limit of detection (LOD) and limit of quantification (LOQ) of TSP measurement methods are often not distinctly specified, but experience shows that an accuracy of +/- 5 mg/mj with the Austrian/German method is reasonable. This accuracy increases with decreasing concentrations of coarse fly ash particles in the flue gas (less influence of isokinetic sampling, nozzle diameter and deposits in the sampling line) as well as lower concentrations of condensable organic compounds in the flue gas (less wall losses in the sampling line), thus also making a reliable measurement at the ultra-low emission levels of the UleWIN technology possible. Moreover, for this technology the fine particle emissions were additionally determined with low-pressure cascade impactors, which allow a higher accuracy at low TSP emission levels than other TSP-measurements. 10 See ANNEX II: Requirements in product standards and regulations, Table

19 Table 1: Overview of the emission test methods Emission Test method Reference Method Maximum uncertainty TS Austrian / German (undiluted) Norwegian (diluted) ± 5 mg/mj UK 2 possible methods: TSP pren :2013, Annex G 1.) Gravimetric, heated filter method, undiluted (EN ) + OGC measurement + Calculation of total particulate emission 2.) Diluted method: Allowed for specific countries ± 15 % 2 % of the full scale Uncertainties for individual parts of the measurement OGC TS ± 15 % pren :2013, Annex F Flame ionization detector (FID), EN13526, EN % of the full scale EN Non-dispersive infrared spectrometry ± 10 % of the measured value or ± 10 ppm CO EN13240 According to TS15883 ± 5 % pren : % of the threshold limit value of 0.3 % 13 % O 2 TS Chemiluminescence ± 5 % of the measured value or ± 15 ppm NO x pren :2013, Annex E Chemiluminescence (Reference method according to EN 14792) Alternative methods: Source: Comparison by Wuppertal Institute (2014) Non-dispersive infrared (NDIR) method Nondispersive ultraviolet method (NDUV), (ISO 10849:1996) Nonextractive (in situ) method (ISO 10849:1996) 2 % of the full scale (Note: A typical full scale is 1,000 ppm; Table A.1 - Uncertainty of measurement) 18

20 3.3. Product test standard emissions and real-life emissions It can be summarized that the applicable product test standards currently do not report reallife emissions covering all occurring operating conditions of the analysed appliances or the whole combustion cycle. They only include those operating conditions, which are mostly static and/or which can be easily reproduced under synthetic test stand conditions. In the field, many factors like user misbehaviour or cold start of the combustion may have a huge influence on the total emission performance of an installation. An important condition in the type tests to achieve lowest possible emissions is the use of the best fuel quality available, what will be one of the main differences to the real market, where the end-customer is commonly buying the fuel with lowest possible price and therefore most likely fuel of lower quality. 19

21 4. Technologies 4.1. Product categories covered by the project All over Europe, a broad spectrum of different technologies for solid biomass based residential heating is in use. The most relevant technologies for direct heaters (e.g. stoves) and indirect heaters (boilers) are: Logwood boilers Logwood stoves Pellet boilers Woodchip boilers While modern pellet, woodchip and logwood boilers already have achieved a technological performance, which is, in respect to CO and OGC emissions, close to the level of oil and natural gas fired heating systems, the corresponding emissions of stoves are still significantly higher. However, concerning TSP emissions, all present solid biomass combustion systems show higher values compared to oil and natural gas heating systems. Therefore, the EU-ULD project is based on the following overall strategy in order to achieve an efficient emission reduction for solid biomass based residential heating in Europe, especially regarding TSP emissions. In general, primary and secondary measures can be applied for emission reduction. The application of primary measures aims at directly influencing the emission formation process and should therefore be seen as the preferable option. Secondary measures (e.g. particle abatement systems) should be applied when all other emission reduction potentials achieved by primary measures have already been fully utilised or in cases where primary measures cannot be applied (e.g. retrofitting of existing appliances). The potential for further emission reductions by primary measures is thereby strongly associated with the present state-of-theart of the respective technologies and therefore needs to be evaluated for different SCI technologies separately. In the following, it is briefly described, how wood chip and wood pellet boilers, the logwood stove and the ESP-technology, which have been demonstrated within the EU-ULD project, can support an overall European emission reduction strategy for biomass solid fuel based residential heating systems. With the ESP, a secondary measure for TSP-emission reduction has been demonstrated as retrofitting option. While the first strategy based on primary measures can only be applied for new appliances, secondary measures offer also the possibility to upgrade or complement existing heating systems in order to reduce their TSP emissions significantly. By the combination of appropriate primary measures with secondary measures also ultra-low emissions operation can be achieved for new wood log stoves and BAT logwood boilers. Together, the four product categories analysed in the project cover the most significant part of the solid fuel SCI market in Europe. Other product categories have not been specifically considered, as such products could in principle also be replaced by SCI based on ULD technology (e.g. closed fireplaces could be substituted by APS stoves). 11 As agreed by the consortium, due to the poor data available and the negligible number of units installed (no significant influence on the total emissions in EU-27 is expected), systems fired with non-woody biomass solid fuels have not been considered for the scenario calculations. 11 Regarding the replacement of old solid fuel biomass SCI by new products, space issues at the installation site have to be considered, as new appliances are frequently characterised by larger dimensions. 20

22 In the context of the defined emission reduction strategy, the consortium set very ambitious performance targets - in terms of Total Suspended Particle (TSP) emissions - for the demonstrated technologies: A completely new developed ultra-low emission wood pellet and wood chip boiler technology (UleWIN) aiming at reaching ultra low TSP emissions of less than 1 mg/mj NCV (reduction by a factor of at least 10 relative to BAT). An ultra-low TSP emission solution for logwood stove technology characterised by TSP emissions below 5 mg/mj NCV when combining a new developed low-emission logwood stove technology (APS) and an ESP. A newly developed small-scale ESP to enable an ultra-low TSP emission operation also for BAT logwood boilers as well as a low TSP emission operation for old logwood boilers and old logwood stoves and consequently to reach low emissions for retrofitted old boilers or stoves of less than 20 mg/mj NCV (reduction by a factor of at least 5). Figure 1: Scheme of the strategic approach Pellet and chipped fuel boilers Wood fuels Logwood boilers State-of- old the-art technologies State-ofthe-art Logwood stoves old technologies WHtech UleWIN SUPRA APS stove Low emission stoves RuFF ESP RuFF ESP RuFF ESP RuFF ESP Ultra-low emission pellet boilers Ultra-low emission stoves Low emission stoves Ultra-low emission boilers Low emission boilers Primary measures (advanced or new technologies) Secondary measures (filters) Scheme of the strategic approach to provide solutions for (ultra-) low emission operation for all relevant residential solid biomass combustion systems in Europe Source: EU-ULD project (2014) 21

23 4.2. Standard technologies on the market (Base Case) For the aforementioned product categories (see Chapter 4.1), typical standard products (socalled Base Cases or BC ) have been identified for comparison with ULD technologies and in order to define a baseline for the Business as Usual (BAU) scenario in the performed scenario calculations. Thereby, BAU assumes that current policy measures on Member State level will not change and no further action at EU-level will be taken to improve efficiency and to reduce emissions from solid fuel small combustion installations. It assumes a continuation of existing tendencies regarding size, use, efficiency and specific emissions of appliances sold on the market. The Ecodesign Lot15 Preparatory Study provides a comprehensive overview of the relevant BC for the analysed product types. However, as the study was completed already in 2009, new assumptions were discussed with the project partners and taken into account, based on more recent sources. 12 In this report, four types of solid fuel small combustion installations are distinguished (see Chapter 4.1), whose Base Case properties for the reference year 2012 are summarised in Table 2. Table 2: Main figures of the Base Case technologies TECHNOLOGY Name Applicable standard Wood log stove Wood pellet boiler Wood chip boiler 13 Wood log boiler 14 EN EN EN EN ENERGY USE Nominal heat 15 (kw) output Efficiency (NCV %) 70 % 88 % 88 % 88 % Dominating fuel Wood Pellets Chips Wood USE PATTERN Hours of use per year (hours/year) 337 1,400 1,500 1,500 Product lifetime (years) Product price (Euro/unit) 2,000 6,000 15,000 5,000 ECONOMIC INPUTS ELECTRICITY CONSUMPTION Installation costs 16 (Euro/unit) 500 2,000 2,500 1,500 Repair and maintenance cost (Euro/unit over lifetime) , Average 17 (kwh/year) Test standard CO (mg/mj) 3, EMISSIONS (nominal load) Test standard OGC (mg/mj) Test standard 18 (mg/mj) TSP Source: Test standard NO x (mg/mj) Based on Ecodesign Lot15 Preparatory Study (values are indicative and do not reflect a specific real world appliance) and EU-ULD project (2014) E.g. BLT Francisco Josephinum Wieselburg (Austria); HKI (Germany) or Flamme Verte Label (France). In the Lot15 preparatory study, the chip boiler was a non-domestic one with 160 kw nominal heat output. Small domestic down draft (DD) gasifying boiler. Figures for the base year. In the future, the size of new SCI is assumed to decrease by 2 % per year due to the improved insulation of buildings. Without the installation of the system itself (chimney, etc.). Based on electricity consumption in nominal load and stand-by operation. Note: TSP values according to EN

24 4.3. Current Best Available Technologies (BAT) For each identified Base Case technology, there are currently products on the market, which already have a better performance in terms of energy efficiency and (especially TSP) emissions. As basis of the assumptions for such Best Available Technologies (BAT), the BAT figures of the Ecodesign Lot15 Preparatory Study 19 have been considered and updated by data of more recent products placed on the European market (Table 3). 20 Table 3: Main figures of the Best Available Technology TECHNOLOGY ENERGY USE Name Wood log stove Wood pellet boiler 21 Wood chip boiler 21 Wood log boiler 22 Applicable standard EN EN303-5 EN303-5 EN303-5 Nominal heat output (kw) Test standard efficiency (nominal load) (NCV %) 82 % 94 % 93 % 91 % Dominating Fuel Wood Pellets Chips Wood USE PATTERN Hours of use per year (hours/year) 337 1,400 1,500 1,500 Product lifetime (years) Product price (Euro/unit) 2,190 6,900 17,500 6,305 ECONOMIC INPUTS ELECTRICITY CONSUMPTION EMISSIONS (nominal load) Installation costs 23 (Euro/unit) 500 2,000 2,500 1,500 Repair and maintenance cost (Euro/unit over lifetime) , Average 24 (kwh/year) Test standard CO (mg/mj) Test standard OGC (mg/mj) Test standard TSP 25 (mg/mj) Source: Test standard NO x (mg/mj) Based on Ecodesign Lot15 Preparatory Study See Task 6: Test reports of boilers published by BLT Wieselburg (see: and the Bafa-database (see: No condensing boiler technology considered. Small domestic DD gasifying boiler. Without the installation of the system itself (chimney, etc.). Based on electricity consumption in nominal load and stand-by operation. Note: TSP values according to EN

25 4.4. UltraLowDust technologies (ULD) As mentioned in Chapter 4.1, advanced technologies have been developed and demonstrated within the project during two winter seasons (2011/2012 and 2012/2013). A short description of each technology can be found in this chapter UleWIN boiler technology developed by Windhager During the last years, together with BIOS Bioenergiesysteme and Graz University of Technology, Windhager has developed a completely new boiler concept named UleWIN technology (Ule is the abbreviation for Ultra low emission and WIN for the company name Windhager). This technology has the potential to define a new state-of-the-art regarding small-scale pellet and wood chip combustion. In order to reach the aim of almost zero TSP, OGC and CO as well as reduced NO x emissions, a special two-stage burner has been developed to provide a complete combustion and to minimise emissions of organic aerosols. In addition, due to the low excess oxygen, the thermal efficiency of the system increases. The new technology has been extensively tested at a test stand and in field. Three boilers were running with pellets with a nominal load of 15 kw, another three boilers were operated with wood chips and pellets with a nominal load of 60 kw. In Table 4 and Table 5 the final results of the emission measurements as well as the thermal efficiencies are presented and compared with the present BAT boilers. Table 4: Main figures of boilers with UleWIN-technology TECHNOLOGY ENERGY USE Name Wood pellet boiler Wood chip boiler Applicable standard EN EN Nominal heat output (kw) Efficiency (nominal load) (NCV %) 92 % % 27 Dominating Fuel Pellets Chips USE PATTERN Hours of use per year (hours/year) 1,400 1,500 Product lifetime (years) Product price 28 (Euro/unit) 8,900 19,500 ECONOMIC INPUTS Installation costs 29 (Euro/unit) 2,000 2,500 Repair and maintenance cost (Euro/unit over lifetime) 850 2,125 ELECTRICITY CONSUMPTION Average 30 (kwh/year) CO (mg/mj) EMISSIONS (nominal load) OGC (mg/mj) 1 1 TSP (mg/mj) 1 2 Please note: Figures for nominal load operation Source: EU-ULD project (2014) NO x (mg/mj) Figures according to bench test, based on EN type testing conditions (no official EN type testing performed yet). Efficiency figures measured without serial-production ready insulation of the boiler casing. Therefore, a higher efficiency for the serial product can be expected. Considering the cost of the sole boiler. Without the installation of the system itself (chimney, fuel storage, fuel feed, heat distribution, etc.). Based on electricity consumption in nominal load and stand-by operation. 24

26 Table 5: UleWIN-technology compared with BC and BAT boilers Wood Pellet Boiler ULD 31 (UleWIN) BC Improvement (UleWIN vs. BC) BAT Improvement (UleWIN vs. BAT) Energy efficiency (NCV %) 92 % % + 5 % 94 % - 2 % CO (mg/mj) % % OGC (mg/mj) % 1-8 % TSP (mg/mj) % 9-88 % NO x (mg/mj) % % Wood Chip Boiler ULD 31 (UleWIN) BC Improvement (UleWIN vs. BC) BAT Improvement (UleWIN vs. BAT) Energy efficiency (NCV %) 92 % % + 5 % 93 % - 1 % CO (mg/mj) % % OGC (mg/mj) % 1 0 % TSP (mg/mj) % % NO x (mg/mj) % % Please note: Figures for nominal load operation Source: Based on Ecodesign Lot15 Preparatory Study and EU-ULD project (2014) Compared to Base Case technology, the improvements are high in terms of energy efficiency and impressing in terms of emissions. Table 5 shows that with the new UleWIN technology the total dust emissions from small-scale pellet and especially from wood chip combustion can be further reduced significantly, also compared to the present state-of-the-art appliances. Regarding CO and OGC emissions the system can be categorised as almost zero emission technology. Even at part load operation (30 % of nominal load) 33 the results show that the UleWIN concept can achieve similar low emissions and high energy efficiencies (92 %). In principle, the UleWIN technology can be additionally combined with condensing boiler technology, which would even further improve the overall performance of the system. However, even without condensing technology, the demonstrated new ULD technology will increase the acquisition costs of the boilers. The end-user price is up to 20 % higher compared to the respective BAT boilers Figures according to bench test, based on EN type testing conditions (no official EN type testing performed yet). Efficiency figures measured without serial-production ready insulation of the boiler casing. Therefore, a higher efficiency for the serial product can be expected. See ANNEX I: Part load performance of the demonstrated technologies. 25

27 APS stove technology developed by SUPRA SUPRA has developed a new low emission logwood stove technology (the APS - Active Power System ). It enables a permanently controlled combustion and is applicable for systems with a nominal heat output between 5 and 15 kw. The APS technology allows a higher efficiency with lower wood consumption as well as a significant emission reduction compared to conventional stove concepts. The technology development has been performed in two phases. The first phase was dedicated to the development of a new combustion concept in order to reach high performances regarding emissions. An efficiency of 86 % (NCV) was achieved at nominal load by increasing the combustion temperatures and through the introduction of secondary air (Figure 2, Item 8, above part) for a staged combustion. The second development phase was focused on the implementation of an automatic control system to realise especially an improved combustion during the ignition and burn out phase of the stove. The automatic control measures also prevent in particular user-induced errors regarding air supply and air staging strategies in order to achieve a low emission wood stove. Due to this new control, the heat output of the stove became also considerably more stable during the whole batch combustion. Figure 2: Schematic drawing of the SUPRA APS stove technology Explanation: 1. Combustion chamber 2. Heat exchanger 4. Total air entrance 5. Ignition valve 7. Air entrance for the cleaning of the window 8. (At the bottom) Primary air 8. (Above) Secondary air 9. Ash box 10. Room heating air outlet 11. Ambient air inlet 14. TWEEN under-draught compensator Source: SUPRA (2013) The stable operation of the new APS stove technology is especially of relevance for the permanently growing market of appliances in low energy buildings as well as for the application in Mediterranean regions. In contrast, Base Case stoves are characterized by a fluctuating heat output that might create uncomfortable heating conditions for the users. In Table 6 and Table 7 the achieved emissions and efficiencies of the new APS technology are presented and compared with data from conventional (BC) as well as BAT logwood stoves. 26

28 Table 6: Main figures of the APS stove TECHNOLOGY ENERGY USE Name Wood log stove (APS), Lab test 34 Wood log stove (APS), Type test 35 Applicable standard EN EN Nominal heat output 36 (kw) Efficiency (nominal load) (NCV %) 86 % 84 % Dominating Fuel Wood - USE PATTERN Hours of use per year (hours/year) Product lifetime (years) 28 - Product price (Euro/unit) 3,500 - ECONOMIC INPUTS Installation costs (Euro/unit) Repair and maintenance cost (Euro/unit over lifetime) ELECTRICITY CONSUMPTION EMISSIONS (nominal load) Average 37 (kwh/year) 23 - CO (mg/mj) OGC (mg/mj) TSP (mg/mj) 22 3 NO x (mg/mj) Source: Based on EU-ULD project and type test results of the APS stove (2014) Table 7: APS-technology compared with BC and BAT wood log stoves (nominal load) APS Stove Lab test 34 Base Case Improvement (APS vs. BC) BAT 38 Improvement (APS vs. BAT) Energy efficiency (NCV %) % % CO (mg/mj) 577 3,000-81% % OGC (mg/mj) % 53-43% TSP (mg/mj) % 27-19% NO x (mg/mj) % % Type test 35 Energy efficiency (NCV %) % % CO (mg/mj) 517 3,000-83% % OGC (mg/mj) % 53-66% TSP (mg/mj) % 27-89% NO x (mg/mj) % % Source: Based on Ecodesign Lot15 Preparatory Study, ULD project and type test of the APS stove (2014) EU-ULD Laboratory tests consider the complete combustion cycle from combustion chamber door closed until flame extinguished. The results obtained in the laboratory tests are used for the EU-ULD scenario calculations. Please note: Type test results of the APS wood log stove are based on a different measurement approach than the EU-ULD Lab tests and especially TSP emission values may include significant methodical deviations. Figures for the base year (In the future, the size of SCI is assumed to decrease by 2% / a due to the EPBD) Based on electricity consumption in nominal load and stand-by operation. Note: BAT performance was derived from EN product certification database values. 27

29 ESP technology developed by RUFTEC Figure 3: Source: TFZ (2014) Schematic drawing of the ESP The amount of TSP emitted by biomass stoves and boilers (e.g. fuelled by logwood, pellets or wood chips) is still significantly higher compared to applications fired with gaseous or liquid fossil fuels. With its improved technology the Ruff-Kat ESP offers a promising solution to reduce these emissions. The electrostatic precipitator (ESP) is mounted on top of the chimney (Figure 3) where it can be operated with existing boilers, stoves, and cookers as a retrofit unit as well as in combination with new installations in order to reduce TSP emissions. The ESP is suitable for all types of small-scale residential wood combustion systems up to a nominal thermal capacity of 40 kw. With its automatic cleaning system and an automatic controlling unit no additional user effort is required. Due to negligible pressure losses, any disturbances to users are avoided. Measurements performed have shown precipitation efficiencies for TSP (total suspended particulate matter) of 47 to 67 % in field measurements and 58 to 70 % under laboratory conditions. Table 8: Main figures of the demonstrated ESP TECHNOLOGY Name Ruff-Kat ESP ENERGY USE Power range (combustion appliance) (kw th) Up to 40 USE PATTERN Product lifetime (years) 10 ECONOMIC INPUTS ELECTRICITY CONSUMPTION Product price (Euro/unit) 1,200 Installation costs (Euro/unit) 250 On-mode: power (kw) Standby: power (kw) PRECIPITATION EFFICIENCY TSP (%) Source: RUFTEC (2013) 50 % for old SCI (retrofit) / 65 % in combination with APS and BAT wood log boilers Within the EU-ULD project, RUFTEC demonstrated five ESPs connected to different appliances relevant for the project scope with nominal thermal capacities between 6 kw and 30 kw. Concerning the ESP, since this kind of product is relatively new for the power range of SCI, there is no Base Case and therefore only BAT can be considered for a comparison (see Table 9). 28

30 Table 9: Ruftec ESP compared with BAT ESP-technology ESP Unit RUFTEC BAT Precipitation efficiency % (Field measurements) (Laboratory conditions) Power range (combustion appliance) kw th Up to 40 Up to 150 On-mode elec. power W Source: EU-ULD project (2014); BAT-data: TU Graz et al Summary of the UltraLowDust technologies Table 10 presents the main figures of all ULD technologies, including UleWIN wood pellet and chip boilers, as well as the APS stove and a BAT wood log boiler combined with an ESP. Table 10: Main figures of the ULD technologies TECHNOLOGY Name Wood log stove (APS + ESP) Wood pellet boiler Wood chip boiler Wood log boiler (BAT 39 + ESP) Applicable standard EN EN EN EN ENERGY USE Nominal heat output 40 (kw) Efficiency (nominal load) (NCV %) 86 % 92 % 92 % 91 % Dominating Fuel Wood Pellets Chips Wood USE PATTERN Hours of use per year (hours/year) 337 1,400 1,500 1,500 Product lifetime (years) Product price 41 (Euro/unit) 6,058 8,990 19,500 8,316 ECONOMIC INPUTS ELECTRICITY CONSUMPTION Installation costs 42 (Euro/unit) 1,263 2,000 2,500 2,149 Repair and maintenance cost (Euro/unit over lifetime) 1, ,125 1,364 Average 43 (kwh/year) CO (mg/mj) EMISSIONS (nominal load) OGC (mg/mj) TSP (mg/mj) Source: Based on EU-ULD project (2014) NO x (mg/mj) Small domestic DD gasifying boiler. Figures for the base year. In the future, the size of new SCI is assumed to decrease by 2% per year due to the improved insulation of the buildings. Considering the cost of the sole boiler. Without the installation of the system itself (chimney, fuel storage, fuel feed, heat distribution, etc.). Based on electricity consumption in nominal load and stand-by operation. 29

31 5. Technical TSP reduction potentials 5.1. Scenarios The demonstrated technologies and the emission reduction potentials on the individual appliance level have been shortly presented in Chapter 4. Based on the final results of the project and the current political process on EU-level (Ecodesign), adapted macro-scale scenarios have been analysed, in order to show the additional technical emission reduction potential of the demonstrated technologies for the EU-27 countries as well as to allow a comparison of different options for policies and measures. The following chapter presents the assumptions for the EU-ULD scenario calculations as well as the respective results for TSP emissions in the EU-27. The comprehensive results - including energy consumption, emissions (CO, OGC, NO x, GHG), costs, employment, etc. - are part of the final overall environmental and socio-economic Impact Assessment (D5.6) performed in Work Package 5 of the project. For wood log stoves, the following scenarios including APS and ESP technologies are presented: - Business as Usual Scenario (BAU): Only Base Case stoves will be purchased in the future. This is the baseline reference scenario; - EcoDesign scenario: As of , every new stove purchased on the EU market will fulfil the requirements of the Lot20 Ecodesign proposal (July 2013), (Assumption: 100 % market share for products complying Ecodesign as of 2018); - LowDust scenario (LD): As of 2018, every new wood log stove will be an APS one (Assumption: APS has a market share of 100 % as of 2018); - UltraLowDust scenario (ULD): As of 2018, every new wood log stove will be an APS one combined with an ESP (Assumption: APS combined with an ESP has 100 % market share as of 2018); - Intermediate scenario: As of 2018, 50 % of the new stoves purchased on the EU market will fulfil the requirements of the Lot20 Ecodesign proposal (July 2013) and the second half will be UltraLowDust appliances (APS combined with an ESP). (Assumption: Products complying with Ecodesign have 50 % market share as of 2018 and APS stoves combined with an ESP have also 50 %); 44 This year has been chosen for all scenarios due to comparison reasons with the Ecodesign proposals (July 2013), which are designated to come into force as of 1 January The assumption of 100 % market share has been chosen to present the maximum possible technical emission reduction potential. 30

32 For boilers, the following scenarios are considered: - Business as Usual Scenario (BAU): Only Base Case boilers will be purchased in the future. This is the baseline reference scenario. - EcoDesign scenario: As of 2018, every new boiler purchased on the EU market will fulfil the requirements of the current Lot15 Ecodesign proposal (July 2013), (Assumption: 100 % market share for products complying Ecodesign as of 2018). - UltraLowDust (ULD): As of 2018, every new wood pellet and wood chip boiler will be an UleWIN boiler (assumption: UleWIN has 100 % market share after 2018). For wood log boilers, the combination of a BAT boiler with an ESP is considered as ULD Intermediate scenario: As of 2018, 50 % of the new boilers purchased on the EU market will fulfil the requirements of the Lot15 Ecodesign proposal (July 2013) and 50 % will be UltraLowDust appliances. (Assumption: Products complying with Ecodesign have 50 % market share as of 2018 and ULD boilers have also 50 %). Since retrofitting with an ESP or early replacement can dramatically reduce especially TSP emissions, two further alternative sub-scenarios have been considered respectively. - Retrofitting option (see scenario _retrofit): In this sub-scenario, as of 2018, existing old appliances which have 10 years remaining lifetime will be retrofitted with an ESP (10 years are the estimated lifetime of the ESP). - Replacement option (see scenario _replace): In this sub-scenario, as of 2018, existing old appliances with 10 years remaining lifetime will be replaced by a new one, which complies the requirements for new products of the respective scenario. Regarding the real-life performance of SCI, within the consortium it has been discussed and concluded that, based on the available data, the real-life emission performance of the different heating systems cannot be calculated. 46 For a statistically reliable calculation of the correlation between test stand measurements and real-life emissions, a much broader database and significantly more effort would be needed. Regarding the fuel efficiency, general reduction factors have been defined for the scenario calculations in order to estimate the real-life performance based on the test stand efficiency :46 : - Real-life performance of boilers = Test stand efficiency - 15 % - Real-life performance of stoves = Test stand efficiency - 5 % Since UleWIN technology cannot be applied to wood log boilers. D5.5 Final environmental performance analysis of the technologies demonstrated. 31

33 The scenarios presented in this document include also the general assumption that the typical size of appliances will decrease in the future as expected effect of the Energy Performance of Buildings Directive 2010/31/EU (EPBD). Accordingly, the annual emissions per appliance will also decrease in all scenarios. The total emissions are calculated based on the real-life efficiency of the SCI, as described above. The following figures in the Chapters 5.2 to 5.6 show the development of TSP emissions until the year 2050 as calculated from the different scenarios, including information about the stock volume of small combustion appliances. In all scenarios, TSP emissions can be reduced massively compared to BAU, although the stock volume further increases from 2017 to Wood pellet boilers As presented in Figure 4, in 2037, while 6,723 t/year are emitted in the BAU scenario, the TSP emissions are almost negligible in the ULD scenario (191 t/year) and far below the emissions of the EcoDesign scenario (1,914 t/year). Assuming a replacement program for existing old appliances with ULD technology (ULD_replace scenario), the total TSP emissions would reach the level of 161 t/year already by 2027 (- 97 % compared to BAU, - 96 % compared to EcoDesign and - 95 % compared to ULD). By this means, 10 years after the implementation of policies or measures to achieve ULD level for the whole stock, the TSP emission level could be maintained below 200 t/year over the following two decades, although the stock volume still increases. The Intermediate scenario represents a mixture of EcoDesign and ULD scenarios, as described in Chapter 5.1. Figure 4: TSP emissions and stock volume (wood pellet boilers in EU-27) t Units BAU EcoDesign EcoDesign_retrofit EcoDesign_replace ULD ULD_retrofit ULD_replace Intermediate Intermediate_retrofit Intermediate_replace Stock volume (units) Source: Wuppertal Institute (2014) 32

34 5.3. Wood chip boilers For wood chip boilers, similar scenarios as for wood pellet boilers have been calculated. Figure 5 shows the main results. Also in the ULD scenario for wood chip boilers, the UleWIN technology has the potential to reduce TSP emissions massively within 20 years despite a large expected increase of the stock volume. In 2037, only 459 t/year are emitted in the ULD scenario, which is 94 % below the emission level of the BAU scenario (8,071 t/year) and 79 % below EcoDesign (2,214 t/year). By replacing old boilers in the stock (_replace scenarios), the emission reduction can be extremely accelerated in the first 10 years. The Intermediate scenario represents a mixture of EcoDesign and ULD scenarios, as described in Chapter 5.1. Figure 5: TSP emissions and stock volume (wood chip boilers in EU-27) BAU EcoDesign EcoDesign_retrofit EcoDesign_replace t Units ULD ULD_retrofit ULD_replace Intermediate Intermediate_retrofit Intermediate_replace Stock volume (units) Source: Wuppertal Institute (2014) 33

35 5.4. Wood log boilers For wood log boilers, similar scenarios have been calculated. Figure 6 shows the main results. While the whole stock of wood log boilers is expected to remain in the range of about 5 million appliances between 2017 and 2037, even in the BAU scenario the TSP emissions will decrease from 37,624 to 25,550 t/year due to both, the replacement of old installations, which reached the end of their technical lifetime, as well as the assumed decreasing size of the SCI as an effect of the Energy Performance of Buildings Directive (2010/31/EU, EPBD ). For the same reason, although the stock is expected to grow to more than 7.5 million units in 2050, the increase of emissions can be significantly slowed down. Ecodesign is a powerful instrument to decrease the TSP emissions in a medium-term, e.g. to 7,235 t/year by 2037 (- 72 % compared to BAU). The ULD scenario shows that TSP emissions could even be reduced to 2,499 t/year (- 90 %) by a combination of BAT wood log boilers with ESPs. However, in the ULD_replace scenario a much faster reduction can be achieved already by 2027 (- 76 % compared to BAU, - 64 % compared to EcoDesign, and - 59 % compared to ULD). The Intermediate scenario represents a mixture of the EcoDesign and ULD scenarios, as described in Chapter 5.1. Overall, the ULD scenarios show that the best way to achieve large and rapid TSP emission reductions is to combine ambitious requirements for the new SCI on the market (ULD level) with measures for the stock (retrofit of existing SCI or even better replacement by new appliances complying high performance requirements). Figure 6: TSP emissions and stock volume (wood log boilers in EU-27) t Units BAU EcoDesign EcoDesign_retrofit EcoDesign_replace ULD ULD_retrofit ULD_replace Intermediate Intermediate_retrofit Intermediate_replace Stock volume (units) Source: Wuppertal Institute (2014) 34

36 5.5. Wood log stoves As shown in Figure 7, there is a significant TSP emission reduction potential by applying all technologies demonstrated in the project relevant for wood log stoves (see ULD scenario). For wood log stoves, UltraLowDust" corresponds to an APS stove combined with an ESP. An additional scenario was considered with the assumption that every new wood log stove purchased on the market is a LowDust APS stove without the additional ESP (see LD scenario). In the BAU scenario, there is a relative decoupling of emissions and stock development as a result of the assumed reduction of the heat demand induced by the EPBD and also by the replacement of old end-of-life SCI with better performing new SCI. However, the overall BAU TSP emissions in the analysed period will remain on a high level of up to 72,000 t/year. In contrast, the implementation of the Ecodesign proposal (July 2013) would already have a powerful absolute decoupling effect on total TSP emissions from wood log stoves, which could be reduced to 11,935 t/year by In the ULD scenario, the level of TSP emissions can be further reduced by another 73 %. In all scenarios, a progressive retrofit (with an ESP, see _retrofit scenarios) or even replacement strategy (see _replace scenarios) for existing SCI would strongly accelerate the emission reduction path. Technically, as shown in the ULD_replace scenario, a TSP emission level of about 10,000 t/year would be achievable already by The Intermediate scenario represents a mixture of EcoDesign and ULD scenarios, as described in Chapter 5.1. Figure 7: TSP emissions and stock volume (wood log stoves in EU-27) BAU t Units EcoDesign EcoDesign_retrofit EcoDesign_replace LD LD_retrofit LD_replace ULD ULD_retrofit ULD_replace Intermediate Intermediate_retrofit Intermediate_replace Stock volume (units) Source: Wuppertal Institute (2014) 35

37 5.6. Conclusion Chapter 5 presented different TSP emission scenarios for each product group relevant for the project scope, as well as two sub-scenarios respectively with measures for the stock (retrofit and replacement of existing installations). Figure 8 shows the results for all product groups combined for the scenarios addressing new appliances. Due to the assumed reduction effect of the EPBD on the heat demand of buildings and the autonomous replacement of old end of life products, the TSP emissions in the BAU scenario can be hold steady close to 110,000 t/year in the next decades, although the stock of installed SCI is expected to double in the same period (relative decoupling). With Ecodesign, even an absolute decoupling of the total TSP emissions and the number of installed SCI will be possible and consequently the TSP emissions would decrease significantly. However, since also Ecodesign addresses only the market and not the stock, the full emission reduction effect of such a policy will be reached by 2045 at the earliest, as especially wood log stoves are characterised by a long technical lifetime (typically 28 years). The project demonstrated technologies, which would even have the potential to reduce the overall TSP emissions to a much greater extent down to 6,487 t/year by 2045 (see Figure 8, ULD scenario). Figure 8: Total TSP emissions and stock volume in EU-27 (scenarios for the market) t Units BAU EcoDesign ULD Stock volume (units) Please note: Overview of the development of the total emissions, including all technologies covered in this report Source: Wuppertal Institute (2014) Also considering the figures for all types of covered SCI, in order to accelerate the TSP emission reduction, addressing the market and therefore only newly purchased appliances will not be sufficient. The sub-scenarios _retrofit (with an ESP) and _replace (with a new SCI) show evidences that existing appliances are playing a key role for an accelerated reduction of the overall TSP emissions from this source in EU-27 (see Figure 9). 36

38 Assuming the ideal case with the combination of ULD level for SCI on the market and an early replacement of existing SCI by such an ULD product, TSP emissions in the ULD_replace scenario could be reduced to 38,181 t/year already in 2027 (66 % below BAU, 50 % below EcoDesign and 44 % below ULD). Figure 9 and Table 11 present a detailed overview of the overall TSP emission reduction potentials in the different scenarios. Figure 9: Total TSP emissions and stock volume in EU-27 (incl. scenarios for the stock) t Units BAU EcoDesign EcoDesign_retrofit EcoDesign_replace LD LD_retrofit LD_replace ULD ULD_retrofit ULD_replace Intermediate Intermediate_retrofit Intermediate_replace Stock volume (units) Please note: Overview of the development of the total emissions, including all technologies covered in this report Source: Wuppertal Institute (2014) Table 11: TSP emission reduction potential according to the respective scenarios Scenarios BAU (reference) 104,343 t/y 113,659 t/y 111,848 t/y 110,780 t/y EcoDesign 0 % - 33 % - 62 % - 78 % EcoDesign_retrofit 0 % - 47 % - 69 % - 78 % EcoDesign_replace 0 % - 56 % - 74 % - 78 % LD 0 % - 38 % - 71 % - 89 % LD_retrofit 0 % - 52 % - 78 % - 89 % LD_replace 0 % - 64 % - 84 % - 89 % ULD 0 % - 40 % - 75 % - 94 % ULD_retrofit 0 % - 54 % - 82 % - 94 % ULD_replace 0 % - 66 % - 88 % - 94 % Intermediate 0 % - 37 % - 69 % - 86 % Intermediate_retrofit 0 % - 51 % - 76 % - 86 % Intermediate_replace 0 % - 61 % - 81 % - 86 % Please note: Reference years 2027, 2037, 2047 = Implementation of Ecodesign (Jan 2018) + 10/20/30 years Source: Wuppertal Institute (2014) 37

39 Besides a relative emission reduction, also large cumulated savings can be achieved by ULD technologies over the whole analysed time period. Between 2018 and 2047, in the ULD_replace scenario, a cumulated TSP emission volume of 771,029 t could be saved compared to the EcoDesign scenario (see Table 12) and also a total of 447,498 t compared to the already ambitious ULD scenario (Figure 10). Even larger cumulated savings can be realised in comparison to the BAU scenario. Table 12: Cumulated TSP emission saving potentials Scenarios compared EcoDesign vs. BAU - 213,728 t - 775,007 t - 1,580,765 t ULD_replace vs. BAU - 428,543 t - 1,329,509 t - 2,351,793 t ULD_replace vs. EcoDesign - 214,785 t - 554,502 t - 771,029 t Source: Wuppertal Institute (2014) Figure 10: Cumulated TSP emission saving potential ULD_replace vs. ULD scenario (#!$!!!" (!!$!!!"!"#$%&'((')*($+,-.%/01$ '!$!!!" &!$!!!" %!$!!!" #!$!!!" ULD Name ULD ULD_replace ULD_replace Cumulated TSP emission savings of 447,498 t!" #!()" #!#)" #!*)" #!%)" Please note: Overview of the development of the TSP emissions, including all technologies covered in this report. Green area: Cumulated savings of ULD_replace scenario compared to the ULD scenario Source: Wuppertal Institute (2014) The economic analysis performed within the Impact Assessment (D5.6) shows that full life cycle costs for SCI complying Ecodesign do not exceed those of Base Case level appliances, since the incremental investment to improve the emission performance also leads to a better energy efficiency and can therefore be compensated by reduced energy expenditures. However, policy measures going beyond the Ecodesign level could impose additional costs to the end-users, as long as ULD technology remains more expensive and hazardous emissions from SCI are not monetised. Therefore, specific policy measures aiming at utilising the maximum of the additional TSP reduction potential are necessary and will be discussed in Chapter 7. 38

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41 6. Policies in Europe 6.1. Policies and instruments implemented on EU-level By 2014, there are only few policies and instruments implemented on EU-level related to solid fuel combustion appliances (see Table 13): Table 13: EU directives and conventions related to emissions of solid fuel heaters Policies and instruments Ambient Air Quality Directive (2008/50/EC) AAQD National Emission Ceilings Directive, NECD (2001/81/EC), revision in 2013 Gothenburg Protocol, Protocol to the 1979 Convention on Long-range Transboundary Air Pollution to abate Acidification, Eutrophication and Ground-Level Ozone (amended in 2012) Relevance for solid fuel heaters (indirect effects) Target and limit values for PM 2.5/10 concentration in the ambient air (Annex XIV, ANNEX XI, Section B) Review of the provisions related to PM 2.5 is foreseen (Art. 32) National emission ceilings for Member States In December 2013, the European Commission adopted the new Clean Air Policy Package, including a revision of the NECD under consideration of PM emissions. EU and further countries EU and national emission reduction commitments to be achieved in 2020 and beyond for PM 2.5 and other pollutants Recommended emission limits for SCI (Annex II, Table 12 and 13) EPBD, Energy Performance of Buildings Directive (2010/31/EU) Source: Wuppertal Institute (2014) From 2021 onwards, all new buildings have to be nearly zero-energy buildings (public buildings as of 2019; Art. 9) Member States shall set system requirements covering heating and hot water systems (Art. 8) Regular inspection and reporting (including efficiency) of heaters > 20kW, at least every two years for heaters > 100kW (Art. 14, 16) Thereby, most of these instruments are substantially related to air quality legislation. The Directive on ambient air quality and cleaner air for Europe (2008/50/EC) 47 addresses the immission side and includes air quality requirements for Member States like maximum allowed PM concentrations in the ambient air, to which SCI are contributing. On the emission side, miscellaneous diffuse sources, including SCI, are currently only regulated through the setting of general and holistic national annual emission limits ( ceilings ) for Member States. In this context, the international Gothenburg Protocol (revised in 2012) includes ceilings for PM 2.5, as well as a weak recommendation for TSP emission limits for SCI (26.6 mg/mj or 40 mg/m 13 % O 2 ). The other relevant instrument, the EU National Emission Ceilings Directive, NECD, (2001/81/EC) currently does not cover PM, but according to the new EC Clean Air Policy Package from December 2013 PM will be covered in the forthcoming next edition. Additionally, there are various EU directives generically related to solid fuel heaters. The most relevant of these directives are presented in Table

42 Table 14: EU directives generically related to solid fuel heaters Construction Product Directive (89/106/EEC) Low Voltage Directive (2006/95/EC) Machinery Directive (2006/42/EC) Pressure Equipment Directive (97/23/EEC) CE-marking only if appliances comply with this Directive CE-marking only if appliances containing electrical equipment (50-1,000V AC / 75-1,500V DC) comply with EN 50165:1997 CE-marking only if appliances containing one moving part ( machinery ) comply with this Directive Only applicable if pressures > 0.5 bar are used ATEX Directive (94/9/EC) Directive on equipment and protective systems intended for use in potentially explosive atmospheres (ATEX) Source: Based on Ecodesign Lot15 Preparatory Study and Wuppertal Institute (2014) 6.2. Forthcoming policies and instruments on EU-level EU policies on air quality After many years of EU air quality policy and technical improvements, in many areas in Europe the industrial sector is not dominant anymore with regard to air pollution so that transport and residential heating systems became the main sources for certain airborne pollutants. Diesel motor vehicles and residential solid fuel combustion are main factors for PM and e.g. NO 2 concerns in almost every major city. In this context, the World Health Organization (WHO) concludes that especially PM emissions are always harmful - independent of their origin - and that there is no health safety limit for air concentrations. Consequently, despite the large achievements in the past, the EU map on air pollution levels still shows a lot of hot spots across Europe and about two of three Member States of the EU do not yet meet the existing AAQD limits. Thereby the current EU limits are still twice as high as the WHO recommendations. After a comprehensive review of the EU air policy with the target to address these issues, the new EC Clean Air Policy Package launched in December 2013 includes the revision of the National Emission Ceilings Directive (NECD) as one major cornerstone of EU legislation on air emission control in order to update a proven and effective tool with high rates of compliance among MS by setting stricter new emission ceilings for the 2020 to 2030 period. The update of the NECD will provide strong general incentives for MS to implement farreaching national emission reduction policies, especially because the scope will also cover particulate matter. The new policy package also includes a new EU Directive for mediumsized combustion plants between 1 and 50 MW th covering both, new as well as old existing installations. For a better evaluation of the process, the EU is also working on a comprehensive air quality database. In contrast, even after the revision of EU air quality policies, especially the emission regulation of existing residential small combustion installations will remain a major challenge on EU-level, because the available EU policy instruments like NECD can only have indirect effects on this product group by fostering respective regulations by the Member States. While emissions of larger combustion installations or plants are already directly covered by EU and national regulations, no EU or MS wide regulations (except the German 1.BImSchV) explicitly address both, new as well as existing SCI regarding their emissions, although this would be the most essential way to achieve large and fast emission reductions in the residential heating sector. 41

43 EU policies for new SCI Besides EU air quality policies, a legislative process on the European level has been initiated to regulate the market of new small-scale solid fuel combustion installations (SCI), based on the EU Ecodesign and Energy Labelling Directives EU Ecodesign and mandatory Energy Labelling Within the framework of the EU Ecodesign and Energy Labelling process, relevant energy related products 48 put on the market shall be regulated in order to achieve higher energy efficiency levels. For solid fuel heaters, no final regulation has been enacted yet, but it is under preparation. According to the current proposal documents, solid fuel boilers (indirect heaters) will be regulated separately from direct (room) heaters (e.g. stoves). Solid Fuel Boilers (Indirect heaters) Mandatory Ecodesign for Solid Fuel Boilers In April 2012, the European Commission has started the work on a regulation for solid fuel boilers (Ecodesign ENER Lot 15 - Solid fuel boilers, indirect heaters only) and the first draft for solid fuel installations was discussed during the Ecodesign Consultation Forum in In a next step, the regulation proposal has been notified to the WTO in July 2013 and discussed within the Ecodesign Regulatory Committee in Brussels in autumn However, in the consultation process with the Member States no agreement could be reached in Table 15: Proposed MEPS and ELVs for solid fuel boilers Biomass solid fuel boilers η s PM OGC CO NO x % mg/m 3 (@ 10 % O 2 ) Rated heat output < 20 kw Rated heat output > 20 kw Fossil solid fuel boilers Rated heat output < 20 kw Rated heat output > 20 kw Please note: ELVs for solid fuel boilers are defined in mg/m 10 % O 2, rather than mg/mj as otherwise throughout this document. For conversion: 1 mg/nm 10 % O 2 approx. 0.5 mg/mj (for wood fuels). Source: Ecodesign ENER Lot 15 - Solid fuel boilers, draft regulation, status of January 2014 For comparability to the Ecodesign regulation of boilers using gaseous or liquid fossil fuels (ENER Lot 1), the minimum energy efficiency calculation is also based on the gross calorific value (GCV). 48 Methodology for the Ecodesign of Energy-related Products, MEErP = Update of the Methodology for the Ecodesign of Energy-using Products (MEEuP), 42

44 The current proposal includes one single tier for minimum efficiency performance standards (MEPS) and emission limit values (ELVs) respectively. MEPS and ELVs are intended to come into force about four years after implementation of the regulation. 49 The MEPS are defined by the seasonal space heating energy efficiency (η s ) and the ELVs as seasonal space heating energy emissions (E s ). The seasonal space heating energy efficiency (η s ) is calculated based on the formula: η s = η s,on - F(1) - F(2) + F(3) η s,on is the seasonal space heating energy efficiency in active mode expressed as a percentage and calculated as follows: (1) For manually stoked solid fuel boilers that can be operated at 50 % of the rated heat output in continuous mode, and for automatically stoked solid fuel boilers: η s,on = 0.85 x η p x η n (η n and p expressed in GCV) (2) For manually stoked solid fuel boilers that cannot be operated at 50 % or less of the rated heat output in continuous mode, and for solid fuel cogeneration boilers: η s,on = η n (η n expressed in GCV). F(1) accounts for a loss of seasonal space heating energy efficiency due to adjusted contributions of temperature controls; F(1) = 3 %; F(2) accounts for a negative contribution to the seasonal space heating energy efficiency by auxiliary electricity consumption, expressed as a percentage; F(3) accounts for a positive contribution to the seasonal space heating energy efficiency by the electrical efficiency of solid fuel cogeneration boilers, expressed as a percentage; This calculation introduces weighting factors for part load efficiency and nominal load efficiency in order to account for a more realistic allocation of these operations conditions; Following the same approach, the seasonal space heating energy emissions are calculated: (1) for manually stoked solid fuel boilers that can be operated at 50 % of the rated heat output in continuous mode, and for automatically stoked solid fuel boilers: E s = 0.85 x E s,p x E s,n (2) for manually stoked solid fuel boilers that cannot be operated at 50 % or less of the rated heat output in continuous mode, and for solid fuel cogeneration boilers: E s = E s,n E s,p are the emissions of respectively particulate matter, organic gaseous compounds, carbon monoxide and nitrogen oxides measured at 30 % or 50 % of rated heat output, as applicable and E s,n are the emissions of respectively particulate matter, organic gaseous compounds, carbon monoxide and nitrogen oxides measured at rated heat output. According to the requirements for product information, technical parameters including the level of emissions and the recommendation for a buffer tank will have to be provided together with each appliance (see ANNEX III: Information requirements for Lot 15 and Lot 20 ) January 2018 assuming an implementation of the Ecodesign ENER Lot 15 - Solid fuel boilers draft regulation (status of January 2014) 43

45 Mandatory EU Energy Label for solid fuel boilers Additionally to the obligatory Ecodesign requirements, also the introduction of a mandatory Label for solid fuel boilers is planned, based on the EU Energy Labelling Directive (2010/30/EU). 50 The Label is essentially related to energy efficiency and enacted directly by the European Commission. The Member States are involved in the consultation process, but do not vote on the Energy Label proposals. The current official proposal for the solid fuel boiler labelling scheme (July 2013) includes an Energy Efficiency Index (EEI), which is calculated as follows and expressed in %: EEI = η s,on x BLF - F(1) - F(2) + F(3) Thereby, it is intended to grant a bonus factor for renewable biomass solid fuels, as they affect the efficiency performance of boilers. This bonus is included in the EEI calculation for the labelling class as biomass label factor (BLF), which allows a better differentiation between biomass boilers and fossil fuel boilers, so that the most efficient biomass boilers achieve a better labelling class of at least A+. In the consultation process with the Member States it was also discussed to rank them even one class higher up to A++, but there is no final decision yet. According to the current proposal, this label would be introduced two years after the implementation of the regulation (2016 at earliest, assuming an implementation in 2014) but would not provide any information related to emissions. Thereby, the Energy label might also be implemented independently from Ecodesign. Figure 11: Mandatory Energy Label for solid fuel boilers (Draft) Source: EC 2013 (Draft) 50 Directive 2010/30/EU of 19 May 2010 on the indication by labelling and standard product information of the consumption of energy and other resources by energy-related products. 44

46 Local room heaters (Direct heaters) Mandatory Ecodesign for local room heaters In July 2012, the European Commission issued a Working Document on the possible regulation of local room heating products (Ecodesign ENER Lot 20 as well as former parts of ENER Lot 15 addressing direct heaters only) and the first draft for local room heating products was discussed on the Ecodesign Consultation Forum in In a next step, the regulation proposal has been notified to the WTO in July 2013 and discussed within the Ecodesign Regulatory Committee in Brussels in autumn However, in the consultation process with the Member States no agreement for solid fuel local room heaters could be reached in The current proposal documents include one single tier for minimum efficiency performance standards (MEPS) and emission limit values (ELVs) respectively. MEPS and ELVs are intended to come into force four years after implementation of the regulation (1 January 2018 at the earliest, assuming an implementation in 2014). The MEPS are defined by the seasonal space heating energy efficiency (η s ). The reference for PM measurement is based on the heated sample method without dilution of flue gas. Alternatively, PM can be measured by using natural draft with dilution tunnel (based on g/kg dry fuel input). Table 16: Proposed MEPS and ELVs for solid fuel local room heaters Open fronted solid fuel local space heaters Closed fronted solid fuel local space heaters using solid fuel other than compressed wood in the form of wood pellets Closed fronted solid fuel local space heaters using compressed wood in the form of wood pellets η s PM OGC CO NO x % mg/m 3 (@ 13 % O 2 ) , , Cookers , Please note: ELVs for solid fuel direct heaters are defined in mg/m % O 2, rather than mg/mj as otherwise throughout this document. For conversion: 1.0 mg/mj 1.5 mg/nm % O 2 (for wood fuels). If the dilution tunnel method is used for PM measurement, other ELVs have to be applied. Source: Ecodesign ENER Lot 20 - Solid fuel local room heaters, Draft regulation, January See: room_heating products. 45

47 The seasonal space heating energy efficiency (η s ) for solid fuel local space heaters is calculated based on the formula: η s = η s,on - 10 % + F(1) + F(2) + F(3) - F(4) - F(5) Thereby: F(1) is a correction factor for electrical heaters - Not applicable for solid fuel heaters; F(2) is a correction factor accounting for a positive contribution to the seasonal space heating energy efficiency due to adjusted contributions of controls of indoor heating comfort, the values of which are mutually exclusive, cannot be added to each other, expressed in %; F(3) is a correction factor accounting for a positive contribution to the seasonal space heating energy efficiency due to adjusted contributions of controls for indoor heating comfort the values of which can be added to each other, expressed in %; F(4) is a correction factor accounting for a negative contribution to the seasonal space heating energy efficiency by auxiliary electricity consumption, expressed in %; F(5) is a correction factor accounting for a negative contribution to the seasonal space heating energy efficiency by energy consumption of a permanent pilot flame, expressed in %; η s,on is the seasonal space heating energy efficiency in active mode η s,on = η th,nom The useful efficiency at nominal heat output (η th,nom ) is based on the net calorific value (NCV). According to the requirements for product information, technical parameters including the level of emissions will have to be provided together with each appliance (see ANNEX III: Information requirements for Lot 15 and Lot 20 ). 46

48 Mandatory EU Energy Label for local room heaters As for solid fuel boilers, additionally to Ecodesign requirements, the introduction of a mandatory Label based on the EU Energy Labelling Directive (2010/30/EU) 52 is also planned for local room heaters (Figure 12). The Label is essentially related to energy efficiency and enacted directly by the European Commission. The Member States are involved in the consultation process, but do not vote on the Energy Label proposals. The current official proposal for the solid fuel local room heater labelling scheme (July 2013) includes an Energy Efficiency Index (EEI), which is calculated as follows and expressed in per cent (%): EEI = η s,on x BLF - 10 % + F(1) + F(2) + F(3) - F(4) - F(5) As for boilers, the biomass label factor (BLF) allows a differentiation between biomass and fossil solid fuel room heaters. This label is also intended to be introduced two years after the implementation of the regulation and does not include any information on emissions. Figure 12: Mandatory Energy Label for local room heaters (Draft) Source: EC 2013 (Draft) 52 Directive 2010/30/EU of 19 May 2010 on the indication by labelling and standard product information of the consumption of energy and other resources by energy-related products. 47

49 Voluntary EU Ecolabel and Green Public Procurement (GPP) In order to further promote the best appliances on the market, additional voluntary instruments can be used to supplement mandatory Ecodesign and Energy Labelling. For solid fuel boilers, EU Ecolabel requirements are under preparation in order to provide the basis for a EU-level endorsement label. In addition to energy efficiency or emissions, the EU Ecolabel as voluntary environment endorsement label of the European Commission may also include other environment or health related aspects. The EU Ecolabel for boilers will be implemented, as the vote on EU-level was already positive. Nevertheless, it will come into effect in 2014 at the earliest, as the work for the Ecolabel regarding water-based heaters is linked to the development of the Ecodesign and Energy Labelling draft regulation documents, as the MEPS and ELVs for solid fuel boilers (see Table 17) to qualify additionally for the EU Ecolabel shall be even more ambitious. However, in contrast to Ecodesign, which will come into force 4 years after implementation of the regulation at the earliest, the forthcoming Ecolabel for boilers will be directly applicable for the next 4 years. Table 17: Proposed EU-Ecolabel MEPS and ELVs for solid fuel boilers η s PM OGC CO NO x % mg/m 3 (@ 10 % O 2 ) Automatically stoked Manually stoked Please note: ELVs (seasonal space heating energy emissions) for solid fuel boilers are defined in mg/m 10 % O 2, rather than mg/mj as otherwise throughout this document. For conversion: 1 mg/nm 10 % O 2 approx. 0.5 mg/mj (for wood fuels). Source: EC, Joint Research Centre (2014) 53 The EU Ecolabel can also be used as Green Figure 13: EU Ecolabel and GPP label Public Procurement (GPP) criteria 53 in order to promote sustainable products, like heating systems with a significantly improved environmental performance, using the vast purchasing power of the EU Member States. Green Public Procurement (GPP) is defined as a process whereby public authorities seek to procure goods, services and works with a reduced environmental impact throughout their life cycle when compared to goods, services and works Source: (2014) with the same primary function that would otherwise be procured (COM 2008/400: Public procurement for a better environment ). By this means, the implementation of GPP can generally pave the way towards more sustainable investments in innovative green technologies. However, due to this focus on GPP, no EU Ecolabel is planned so far for solid fuel room heaters, as such products - developed mainly for the residential heating sector - have no relevance for usually larger public buildings and consequently for Public Procurement. 53 See: and 48

50 6.3. National policies and instruments in the EU Member States Mandatory regulations Regulation for new SCI The solid fuel heater market and the policy landscape in Europe present a highly heterogeneous picture. Only a small group of countries has adopted binding ELVs, which are generally measured according to EN standards. This group consists of central European countries (AT, DE, BE) and Scandinavian countries (DK, SE, FI). However, national regulations vary widely in terms of which and how strictly emissions like TSP ( dust ), CO, OGC or NO x are regulated or to which product types regulations apply. Furthermore almost all regulations include only type testing requirements for new products to be put on the market and no requirements for existing installations in the stock. An often-used policy strategy for implementing emission limits is to apply less ambitious limits first and then tighten limits in several steps (tiers). Subsequently, a brief overview of the national PM regulations will be presented. A supplemental overview of regulations on CO, OGC and NO x as well as on efficiency is provided in ANNEX V: Overview of national regulations in the EU. Regulations generally differentiate between product categories such as stoves, boilers, cookers or open fireplaces. In other cases, the differentiation follows characteristics, such as fuel type, operation mode (automatic/manual) or alternative categories (e.g. direct/indirect heaters). Measurement standards and procedures are sometimes prescribed or recommended by legislation and vary across Europe. Chapter 6.3 intends to give a general policy overview for national rules and instruments in the EU Member States and thus avoids more specific differentiations. Important remark on the graphs Because there are substantial technical differences in the national policies, ELVs have been standardised to mg/mj and at an exemplary nominal SCI power of 10 kw. Also, due to the upcoming European regulation differentiating in direct heaters (Lot 20) and indirect heaters (Lot 15), the figures below follow the same differentiation. The subsequent graphs include all countries with implemented regulations for TSP emissions (for other emissions see ANNEX V: Overview of national regulations in the EU ). Countries not listed have no policies on small solid fuel heaters. Countries listed but without data point do not regulate the respective emission type or efficiency. Data points marked in black at level 0 indicate that this policy refers to different units of measurement which can not directly be converted in mg/mj, e.g. mg/h. European EN standards are also listed here for illustrative purposes and do not represent mandatory TSP emission limit values. Especially EN sets indicative performance classes for boilers. In this context, it has also to be highlighted that the German regulation (1.BImSchV) is the only approach in Europe, which includes mandatory emission limits for existing SCI in the stock as well as on-site measurement for all solid fuel boilers. 49

51 Particulate matter (TSP/dust) For direct heaters, there are TSP regulations in AT, BE, DK, DE 54 (and CH). Austrian ELVs are rather high, while ELVs in Belgium start high but will be cut down to mg/mj in the third tier by German ELVs are in a similar range in their second tier as of Figure 14: TSP ELVs in EU countries for direct heaters (mg/mj) 90,00# 80,00# 70,00# 60,00# 50,00# 40,00# 30,00# 20,00# 10,00# 0,00# LowDust wood log stove (APS): 22 mg/mj UltraLowDust wood log stove (APS + ESP): 8 mg/mj PrEN#15544#Qled#stove# EN#15250#slowHrel# EN#14785#part#load# EN#14785#nominal# EN#13240# EN#13229#closed#fp# EN#13229#open#fp+water# EN#13229#open#fp# EN#13229#slowHrel# EN#12815#cookers# slowhrel# United#Kingdom# pellet#stove# wood#2006# dry#stove# open#fire#inset# open#fp# open#fp#2006# wood#1993# UK# 1993# cooker# stove#solid#fuel# pellet# pellet#stove# stove# wood#auto#>#50kw# wood#auto#<50kw# wood#man.#>50kw# wood#man.#<50kw# 1992# 1987# pellet#stove#2015# pellet#stove#2010# cooker+heater#2015# cooker+heater#2010# cooker#2015# cooker#2010# slowhrel#2015# slowhrel#2010# inset#slowhrel#2015# inset#slowhrel#2010# heater#2015# heater#2010# NF#DTU# secondary# primary# DK# pellet#heater#2017# pellet#heater#2014# pellet#heater#2012# insert#2017# insert#2014# insert#2012# stove#2017# stove#2014# stove#2012# auto#2015# auto## 15a#2015# 15a#1998# AT# BE# DK# FI# FR# DE# IR# SE# CH# UK# EU# Please note: Green lines = Emission levels of (Ultra)LowDust wood log stoves Source: Wuppertal Institute (2014) For indirect heaters, ELVs are set in AT, BE, CZ, DK, DE 55, CY (and CH). While limits in Belgium are comparatively high with 200 mg/mj in the first tier today, they will be cut to half by As of 2017, national TSP ELVs will be in the range from 66 mg/mj in BE (maximum for boilers) down to 13 or 20 mg/mj (strictest ELVs for pellet boilers in DE and AT). Figure 15: TSP ELVs in EU countries for indirect heaters (mg/mj) 250,00# 200,00# 150,00# 100,00# 50,00# 0,00# UltraLowDust pellet boiler (UleWIN): 1 mg/mj; UltraLowDust wood chip boiler (UleWIN): 2 mg/mj boilers#<5#mwth# EN#303C5e#auto#class5# EN#303C5e#auto#class4# EN#303C5#auto#class3# EN#303C5e#man#class5# EN#303C5e#man#class4# EN#303C5#manual#class3# EN#15270# EN#12809# boiler#auto# boiler#manual# United#Kingdom# wood#2006# trap.#boiler#manual# boiler#manual# wood#1993# UK# 1993# central#boiler# wood#auto#>#50kw# wood#auto#<50kw# wood#man.#>50kw# wood#man.#<50kw# 1992# 1987# pellet#2015#>4kw# pellet#2010#>500kw# pellet#2010#4c500kw# wood#2016#>kw# wood#2010#>500kw# wood#2010#4c500kw# tr.wood#>500kw# tr.wood#100c500kw# tr.wood#30c100kw# 1998# secondary#>50kw# secondary#<50kw# primary#>50kw# primary#<50kw# >50kW# auto#<50kw# man#>50kw# man#<50kw# boiler# boiler#2017# boiler#2014# boiler#2012# boiler#stove#2017# boiler#stove#2014# boiler#stove#2012# 15a# 15a#2015# 15a#1998# auto#>50kw# manual#>50kw# AT# BE# CZ# DK# FI# FR# DE# IR# SE# CH# UK# EU# CY# Please note: Green line = Emission level of UltraLowDust pellet and wood chip boilers Source: Wuppertal Institute (2014) Germany: For direct heaters, ELVs for new and existing SCI are based on type-testing results. Germany: For indirect heaters, ELVs for new and existing SCI are based on mandatory on-site measurement. 50

52 Regulation for existing SCI So far, Germany is the only country in Europe with a regulation that controls explicitly the emissions of existing small combustion installations in the stock. In Germany, the First Ordinance on the Implementation of the Federal Immission Control Act 1.BImSchV regulates small and medium-sized firing installations. The 1.BImSchV (amended in 2010) is intended to address the four main issues of small scale solid fuel combustion, which are not sufficiently covered by the product standard relevant type testing procedures: Combustion technology, maintenance of the appliances, consumer (mis-)behaviour and fuel quality. For local room heaters (direct heaters) there are MEPS as well as ELVs for CO and dust (TSP) in two tiers (2010, 2015), based on type testing results (see Table 18). For boilers (indirect heaters), there are also ELV requirements, but based on mandatory periodical onsite measurements during operation (see Table 19). The MEPS are NCV based and ELVs are indicated as g/m 3 with reference to 13 % O 2 in the flue gas. Additionally, requirements for a buffer tank are included for boilers. In order to ensure the proper maintenance of the appliances, technical inspections are required every 3 to 4 years for room heaters. Moreover, TSP and CO values have to be measured for all boilers every 2 years. Generally, good practice information on maintenance has to be provided to the end-users through brochures or other suitable information material. The consumer behaviour has also to be tackled through personal consultation for every SCI operator by the chimneysweeper for all new installations and after every change of an operator. The fuel quality is addressed by a list of allowed fuels, which is based on standardised quality requirements where possible (e.g. wood pellets, wood briquettes). For wood quality in general, the use of untreated wood with a humidity of less than 25 % is required. For other biomass solid fuels (straw, grain and similar fuels) additional requirements are defined. Furthermore, the regular inspection of fuel storages is also part of the regulation. The special distinctiveness of the 1.BImSchV is that, after a transition period, the provisions also apply to existing appliances. For boilers this period is 5 to 15 years, depending on the age of the installation. Old room heaters have to be retrofitted (installation of a suitable TSP abatement system) or exchanged after a transition period depending on the date of type testing, which is engraved on the product identification plate. However, for existing stoves less stringent limit values apply than for new ones (Behnke 2013). Table 18: German ELVs and MEPS for direct heaters (type-testing based) Tier 1: Put into operation after 22 March 2010 Tier 2: Put into operation after 31 December 2014 Source: 1.BImSchV (2010) Type of SCI CO (mg/mj) TSP (mg/mj) Efficiency (%), NCV Room heaters 1, Pellet stoves Room heaters Pellet stoves

53 Table 19: German ELVs for indirect heaters (boilers) Rated thermal output CO (mg/mj) TSP (mg/mj) Wood, kw Tier 1: Put into operation after commencement of the regulation Wood, > 500 kw Wood pellets, kw Wood pellets, > 500 kw Tier 2: Put into operation after 31 Dec. 2014, For wood log boilers after 31 Dec Wood, > 4 kw Please note: German ELVs for indirect heaters (boilers) refer to mandatory periodical on-site measurements Source: 1.BImSchV (2010) Voluntary agreements In addition to mandatory emission limits and efficiency requirements, some countries (or regions) have set up labelling schemes in order to pull small biomass solid fuel combustion technology development forward through voluntary labelling, mostly with a focus on thermal efficiency. Existing national labels include the Umweltzeichen 37 (AT) for wood/pellet-fired heaters, the Blue Angel (DE) for pellet stoves and pellet boilers, DINplus marking for room heaters and inserts (DE), Flamme Verte (FR) as well as P-marking (SE) and the sign for ecological safety for boilers (PL). Transnational labelling schemes include the Nordic Swan for slow heat release, stove and insert appliances (SE, DK, FI, NO) or the label of the European Fireplace Association (EFA), which may be applied to solid fuel heaters all over Europe. Figure 16 and Figure 17 present the TSP emission limits as set up by the different labelling schemes. MEPS Requirements are provided in ANNEX V: Overview of national regulations in the EU. The Nordic Swan Label sets requirements in terms of g/g fuel and is therefore not comparable in this graph (marker set at 0). 52

54 Figure 16: TSP labelling requirements in EU countries for direct heaters (mg/mj) 350,00# 300,00# 250,00# 200,00# 150,00# 100,00# 50,00# 0,00# LowDust wood log stove (APS): 22 mg/mj UltraLowDust wood log stove (APS + ESP): 8 mg/mj PLmark#wood# PLmark#pellet#stove# PLmark#pellet#burner# GHS#pellets# GHS#pellets# Flamme#Verte#pellets# Flamme#Verte# UZ37#wChips# UZ37#pellets# UZ37#manual# EFA#pellet#stove# EFA#Bled#stove# EFA#insert# EFA#slowHrel# EFA#heater# Nordic#Swan#pellet# Nordic#Swan#wood# Nordic#Swan#slowHrel# Nordic#Swan#closed#fp# DINplus# Blue#Angel#pellet# DE# Scan# EU# AT# FR# IE# SE# Please note: Green lines = Emission levels of (Ultra)LowDust wood log stoves Source: Wuppertal Institute (2014) Figure 17: TSP labelling requirements in EU countries for indirect heaters (mg/mj) 80,00# 70,00# 60,00# 50,00# 40,00# 30,00# 20,00# 10,00# 0,00# Blue#Angel#pellet# DINplus# Nordic#Swan#<100kW# Nordic#Swan#100D300kW# Nordic#Swan#<300kW#auto# UZ37#manual# UZ37#pellets# UZ37#wChips# UltraLowDust pellet boiler (UleWIN): 1 mg/mj; UltraLowDust wood chip boiler (UleWIN): 2 mg/mj Flamme#Verte#boiler#man.# <50kW## Flamme#Verte#boiler#man.# 50D70kW## Flamme#Verte#boiler#auto.# <50kW## Flamme#Verte#boiler#auto.# 50D70kW## GHS#<10kW# GHS#10D200kW# DE# Scan# AT# FR# IE# DK# SE# PL# wood#manual# wood#auto# pellets#manual# pellets#auto# wchips#manual# wchips#auto# cereals#manual# cereals#auto# straw#manual# straw#auto# PDmark#pellet# temp.#fuel# auto# Please note: Green line = Emission level of UltraLowDust pellet and wood chip boilers Source: Wuppertal Institute (2014) There are very few labels targeting TSP emissions and moreover labelling requirements are also differing a lot. The labels with the strictest requirements are Umweltzeichen 37 and the Blue Angel (for stoves < 15 kw and pellet boilers), followed by the Nordic Swan. The Flamme Verte, P-marking label and EFA label have less stringent requirements, even for pellet appliances. 53

55 6.4. Analysis of the current policy landscape in the EU Chapter 6 has presented an overview over the currently implemented and forthcoming policies and measures, which are related to small-scale biomass solid fuel heating systems. One main finding is that there is a general lack of SCI specific regulations on EU-level. The implemented EU air-quality policies and instruments (e.g. NECD or AAQD, see chapter 6.1) as well as the new EU Clean Air Policy Package adopted in December 2013 do not directly address SCI regarding their emissions and can only induce unspecific pressure on Member States to implement own emission reduction policies and measures. However, the absence of harmonised SCI specific EU emission standards is especially an issue, because de facto currently most of the MS do not have enacted any own sourcespecific national legislation for solid fuel heaters. In addition, for those MS having already implemented regulations, there is generally a large heterogeneity of requirements in terms of emissions covered and the respective level of ambition. For instance, only seven EU countries have regulations for the most relevant emissions at all. Most of the remaining countries have only partial approaches, e.g. on TSP and efficiency, but not on other emissions, or on all emissions but not on efficiency. Concerning existing appliances, only one single European country (Germany) has implemented a regulation with binding performance requirements.56 Figure 18 gives an indicative overview over the TSP regulation and labelling in European countries. In contrast, the forthcoming EU policies on the product and market level (see 6.2.2) could regulate for the first time at least all new SCI to be put on the EU single market. However, this policy process is still on-going. Moreover, the MEPS and ELVs will not specifically foster ultra low emission technologies and they will also not affect existing appliances. Finally, the mandatory EU Energy label will most likely not include any information on emissions. Figure 18: Overview of European TSP regulation and labelling landscape No regulation Only EFA labelling Regulation EFA + other labelling Strict regulation EFA + other strict labelling Source: 56 Wuppertal Institute (2014), based on Figure 16 and Figure 17 In this country, the market for boilers is not regulated, since the performance of boilers has to be checked onsite but not when placed on the market. 54

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57 7. Policy options and recommendations 7.1. Why further policies are required The scenarios presented in Chapter 5 provide clear evidences that emissions caused by biomass solid fuel SCI can be significantly reduced in the near future by fostering new ultra low emission technologies: - The current proposal of Ecodesign with SCI specific requirements for the EU-wide market would have the potential to reduce the TSP emissions in 2047 by 78 % compared to the BAU scenario. - A further scenario taking into account the performance level of the new ULD technologies shows an achievable technical emission reduction potential of 94 % in terms of TSP (73 % below Ecodesign), if only the best SCI - as demonstrated in the project - would be sold from 2018 onwards. - The aforementioned scenarios (Ecodesign and ULD), addressing new products, already present a considerable emission reduction potential compared to the BAU scenario. However, due to the long average product lifetime of SCI, it will take at least 20 to 30 years 57 to have an impact on the whole stock. In this context, additional scenarios, including replacement measures, demonstrate that tackling also the burden of old and poor performing SCI in the stock can accelerate the emission reduction considerably (see Chapter 5.6). 58 Chapter 6 illustrated that there are already policy efforts by the EU and few MS to implement measures for SCI with the intention to increase energy efficiency and to address air quality issues. However, the ULD scenario calculations also show that, besides the current efforts of the EC, including Ecodesign measures for direct and indirect heaters, strong EU wide incentives and additional policy instruments are required to realise the full technical emission reduction potential as far as possible in order to better contribute to an efficient use of renewable energy resources as well as to the achievement of EU Air Quality objectives to reduce major health issues. 59 For this purpose and in the light of the results achieved by the new ULD technologies within the project, Chapter 7 presents comprehensively solid fuel SCI specific policy options and recommendations, which have been discussed within the ULD consortium and with the international experts of the Mirror Group According to the respective average technical lifetime of the SCI. From 2018 to 2047, the aggregated emission reduction potential between the EcoDesign and ULD_replace scenarios accounts for 771,029 t in terms of TSP emissions. Without an appropriate policy package, the market share of ultra low emission technologies (e.g. UleWin boilers) is expected to remain low in the near future (about 10 %, according to an estimation by Windhager). 56

58 7.2. Policy package for new SCI General policy package approach In order to overcome existing barriers and obstacles, market transformation towards better performing technologies has to be initiated and supported by push measures with binding minimum performance standards like Ecodesign with mandatory requirements for efficiency (MEPS) and for emissions (ELVs). To achieve a faster and deeper market transformation, additional pull measures like labelling schemes (including EU Energy- and Ecolabel), financial incentives or Green Public Procurement as well as information and training programs are crucial. Together, a coordinated bundle of several of such policy instruments can form a much more effective policy package 60 (see also Figure 19). Figure 19: Policy package for market transformation Please note: Push policy instruments: = e.g. MEPS, ELVs; Pull : = e.g. Labelling schemes, financial incentives Source: 60 Irrek/Thomas

59 Two steps of improvement As presented in Chapter 6.4, there is no holistic policy package approach for SCI implemented on EU-level yet and most of the relevant EU policy instruments are currently still under preparation (Figure 20). Additionally, some of the instruments, like the proposed mandatory EU Energy Labelling, cover only energy efficiency and will therefore not be sufficient to address the SCI emission issue on EU-level. Figure 20: Current status of the policy package for new biomass solid fuel SCI Performance!Requirements!! (ELVs!&!MEPS)! Labelling!Schemes! Performance!Requirements!! (ELVs!&!MEPS)!!!! EU!Level! Ecodesign!! (in!progress)! Mandatory!Energy!Label!! (in!progress)! Voluntary!Ecolabel!! (in!progress)! Member!State!(MS)!Level! For!new!products!only! No!informa?on!on! emissions! Room!heaters!not!covered! Labelling!Schemes! Incen?ves!and!! Informa?on!programs! Product!Standards! Implemented!in!some! Member!States! Standardisa?on!process!(EN)! Nominal!(and!part!load)! Large!heterogeneity!! of!requirements! Differen?a?on!among!BAT! difficult!and!does!not!reflect! real!life!opera?on! Source: Wuppertal Institute (2014) Beyond the implementation of the policies and measures under preparation, a two-step evolution approach for new SCI is recommended in order to create a more comprehensive policy package on EU-level (see Figure 21): Step 1: Implementation of further developed and more effective pull measures, which are based on existing bench type testing methods. This may particularly include the EU Ecolabel, a new or updated EU Energy Labelling with emission information directly on the label as well as EN product standards including (new) product performance classes. Step 2: Development of new EN product standards, reflecting the progress in ULD technologies and more realistic operation conditions, as well as updates of the corresponding test standards. At the end of this step, the entire SCI policy package - as defined in Step 1 and including MEPS and ELVs - will have to be in line with these new product standards. Accordingly, especially the mandatory performance requirements have to be updated and tightened, if necessary. 58

60 Figure 21: Two-step approach for new solid biomass SCI New$SCI$ European$(EN)$ Step%1:%New$product$ performance$classes$ % Step%2:%New$test$ standards$reflec@ng$uld$ technology$development$ and$more$realis@c$ opera@on$condi@ons$ EU$ELVs$ $ $ EU$Energy$ Label$ $ EU$Ecolabel$ $ $ EU$Green$ Procurement$ Policies$ Addi@onal$policies$and$measures$on$MS$level$(e.g.$financial$incen@ves$for$BAT$/ BNAT,$informa@on$on$good$prac@ce,$networking,$educa@on,$training,$etc.)$ Target$groupOoriented$marke@ng$and$promo@on$by$manufacturers$and$installers$ Source: Wuppertal Institute (2014) The respective EU policy packages should also be complemented by target group-oriented marketing and promotion by manufacturers and installers as well as adequate MS policies (e.g. financial incentives for BAT/ULD, information on good practice, networking with energy auditors, installers and chimney sweepers, education, training, public procurement rules on MS, local or regional level) Step 1: Improving current product information MEPS and ELVs The cornerstone of any policy package with the aim to improve the performance of appliances on the market is the implementation of mandatory minimum performance standards. In the case of biomass solid fuel SCI, MEPS as well as ELVs have to be regulated. Thereby, the Ecodesign proposals for Lot 15 and Lot 20 already include ambitious but achievable requirements as push measure for new biomass solid fuel appliances. With respect to the technologies developed in the course of the EU-ULD project, this would already provide benefits for the market introduction of the APS stove and UleWIN boiler technologies. Despite the EU-ULD consortium supports the current Ecodesign proposals and has developed new technologies with significantly improved performance levels (see Table 20), it is nevertheless too early to suggest even more stringent requirements for a possible future review of the Ecodesign implementing measures. The main reason is that the incremental investment costs of the demonstrated technologies cannot be compensated by lower operation expenses, since negative health and environmental impacts of emissions are not yet internalized and therefore emission reduction has no financial relevance for end users of SCI so far. This means that in the short term much more stringent ELVs, e.g. on ULD level, might even have a counterproductive effect on the biomass solid fuel SCI market and end-users might consequently choose oil or gas technologies with lower purchase costs instead of ultra-low emission biomass solid fuel technologies. 59

61 Table 20: ULD technologies compared to the Ecodesign proposals Ecodesign Energy Label ULD Product category Seasonal Energy Efficiency (%) CO (mg/mj) OGC (mg/mj) PM/TSP (mg/mj) NO x (mg/mj) EEI Energy Class Wood log stove Ecodesign requirements Logwood stove APS Relative Improvement 70 1, B 9 % - 42 % - 43 % - 19 % - 38 % Wood pellet boiler 61 <20kW Wood chip boiler 61 >20kW Ecodesign requirements UleWIN A Relative Improvement Ecodesign requirements 7 % - 93 % - 80 % - 90 % - 56 % UleWIN B Relative Improvement 0 % - 93 % - 80 % - 80 % - 47 % Wood log boiler Ecodesign requirements BAT wood log boiler + ESP A Relative Improvement 2 % - 39 % - 23 % - 65 % 62 0 % Please note: Achieved performance of the demonstrated ULD technologies calculated according to the preliminary Ecodesign methodology (Draft regulation, status of January 2014) Source: EU-ULD project (2014) and Ecodesign Lot15/20 (2014) Because no more stringent performance requirements can be proposed in this step (if the current Ecodesign proposals are implemented as projected), improved product information is one of the key elements, which will enable consumers to make more conscious purchase decisions towards (ultra-) low emission products. Additionally, the improved product information will provide the foundation for emission-based policy packages by Member States as well as for target group-oriented marketing and promotion activities by manufacturers and installers Efficiency figures of the UleWIN boilers are measured without serial-production ready insulation of the boiler casing. Therefore, a higher efficiency for the serial product can be expected. Presumed emission reduction of the RuffKat ESP: 65 % precipitation efficiency in combination with new SCI. 60

62 EU Energy Labelling (Revision) Besides Ecodesign, the mandatory EU Energy Labelling is another powerful EU policy instrument for market transformation towards energy efficient products on the European market. For biomass solid fuel SCI, the market transformation has additionally to be supported towards low or even ultra low emission SCI. However, the current Energy Labelling proposal (July 2013), with focus only on energy efficiency, will not be sufficient to provide a distinction between current BAT products and ultra low emission technologies, because for these high-end products there is no direct correlation between better energy efficiency and lower emissions anymore. Additionally even BAT boilers (with condensing technology) can achieve the upper technical limit for energy efficiency, but not the same low emission levels as ULD products. In order to make this information visible to the end-user and to reflect the additional emission reduction potential by ultra low emission appliances, such as those demonstrated in the EU-ULD project, compared to BAT (typically factor 5 for the boilers), new information requirements on the product label itself are needed. For this purpose, it is recommended to show on the mandatory EU Energy label also information regarding the TSP emissions of an appliance in order to address the most relevant emission parameter for consumers. The information on TSP emissions shall be displayed on the EU Energy Label as follows: - x % better than requirements, if Ecodesign is implemented as proposed with MEPS and ELVs - Otherwise, it is proposed to show an emission class, based on the TSP classes, as defined in Table 21. In order to present biomass solid fuel SCI in a positive manner, 63 Class A will correspond to EN Class 5 TSP emission requirements, while the additional classes A+ and A++ will be reserved for the products with the best emission performance (e.g. Class 6 and 7). 64 Other emission information directly on the label should be avoided because excessive additional emission information (CO, OGC, NO x ) might confuse the end-user at this point. However, in order to make the comprehensive information regarding the emission performance available for the end-users at least in the product booklet, an additional proposal is to include TSP, CO, OGC and NO x emission data for each applicable fuel in the mandatory information material of every appliance (see Table 27 and Table 29 in ANNEX III: Information requirements for Lot 15 and Lot 20 ). The described extensions to the current Energy Labelling proposal with regard to emissions might be also especially relevant because the labelling scheme can be implemented separately and earlier than Ecodesign EU Ecolabelling The EU Ecolabel - the voluntary environment endorsement label of the European Commission - can be an effective instrument for a better promotion and market introduction of ULD technologies. Thereby, the current Ecolabel proposal (2014) includes ambitious requirements for boilers and might already promote ULD technologies. Additionally the ULD consortium supports the idea to develop an Ecolabel also for room heaters, which are not on the official EU-Ecolabel working plan so far. Furthermore, also for particle abatement technologies (e.g. ESPs), a future Ecolabel would be a good opportunity to promote the best products with a high precipitation efficiency and a high operational availability. Based on the results and the experiences gathered during the EU-ULD project, an abatement efficiency of at least 80 % should be the Ecolabel requirement for such technology Since biomass boilers are in competition on the market with dust-free gas boilers. A common alternative approach on the EU Energy Label is also the use of abcdefg' scales. 61

63 Revision of current product standards In order to further promote ULD technologies, EU research programs for new or further revised product and test standards should be supported, including the respective tenders for CEN for a faster adaption of the new standards. Solid fuel boilers (indirect heaters) Currently, the highest product performance Class 5 defined in EN 303-5:2012 does not allow to make a clear distinction between good and very good technologies. For example, the majority of pellet boilers nowadays put on the market already achieve Class 5. Therefore, the introduction of a new Class 6 (or higher) for the very best BAT and ULD products should be considered. Especially a new EN class only achievable by ultra low emission appliances would allow manufacturers to claim a distinct level of product performance based on official and generally accepted technical documents. This could encourage manufacturers to foster innovation even before other mandatory requirements will come into force or will be reviewed. Table 21: Proposal for new EN Classes CO OGC TSP (mg/mj) (mg/mj) (mg/mj) class class class add. BAT ULD class class class class add. BAT ULD class class class class add. BAT ULD class class x class x class x biogenic manual fossil automatic biogenic fossil Please note: The proposed requirements are based on the achieved results of the EU-ULD solid fuel boilers Source: Wuppertal Institute (2014) Solid fuel local room heaters (Direct heaters) Currently, standards for wood log stoves (EN13240/prEN16510) do not include performance classes for appliances defined according to the emission level. However, such classes could be considered for future standards in order to promote also stoves with very low emissions even before other mandatory requirements will come into force or will be reviewed. 62

64 Financial incentives As presented during the Workshops in 2012 and 2013, ULD technologies (especially for smaller appliances with low nominal capacity) face a financial barrier due to the higher investment costs compared to current BAT solid biomass and especially oil and gas heating technologies. Therefore, financial incentives can be an important argument for customers to buy more expensive ULD technology instead of other products. However, tax rebates, subsidies, or other financial incentives to purchase new ultra-low emission products can currently not be implemented or prescribed directly by the EU. Such measures are only possible on Member State level. Even the Structural Funds of the EC (DG REGIO) cannot be used for such purposes, because no direct support of end-users is allowed. The European Investment Bank (EIB) is considering programs for the building stock (e.g. social housing or on district level), but only with a holistic approach for buildings and not for specific building technologies like heating systems. Consequently, the examples for financial incentives in the context of SCI can only be found on Member State level: Example 1: BAFA scheme (DE) The German Federal Office of Economics and Export Control (BAFA) is a superior federal authority subordinated to the Federal Ministry of Economics and Technology (BMWi). In the energy sector BAFA implements measures to promote a better use of renewable energies and the saving of energy. BAFA offers a direct refund incentive, which is applicable for biomass boilers complying the BAFA s own emission requirements, which are more stringent than the mandatory 1.BImSchV regulation. Example 2: CIDD (Crédit d impôt au développement durable) (F) In France the sustainable development tax credit successfully supports the purchase of biomass stoves and boilers fulfilling specific performance criteria. Thereby, the level of tax rebates depends on the situation of purchase (new or replacement of old products) as well as on the extent of the measures for building renovation. Example 3: Voivodeship Fund for Environment Protection (PL) 65 Poland has a well-recognised system for financial subsidies, including the Voivodeship Fund for Environmental Protection and Water Management (WFOŚiGW), which redistributes the financial resources gathered from environmental charges paid by pollutant emitting companies. This money is used by so called Programmes on Low Emission Abatement (PONE). These programmes are operational e.g. since 1998/1999 in the Silesia region and are primarily used to foster the switch from old to state-of-the-art heating systems (see also 7.3.5). Nevertheless, they also promote in general the (market) introduction of new high efficient appliances with low emissions. 65 Kubica, R. (2013), 2 nd Mirror Group Workshop (2013). 63

65 Besides incentives directly initiated by Member States, there are also numerous other existing incentives for biomass heating technologies, implemented on regional or municipal level across Europe. In this context, it is recommended to take multi-level action on EU, Member State and regional level to revise existing financial incentive schemes and to implement new ones, respectively based on the improved product information proposed in Step 1 for new SCI. In contrast to end-users, the whole society will get a financial benefit for reducing emissions in terms of reduced health costs or avoided AAQD-related penalties. Therefore public authorities on all levels should be interested in allocating money for financial incentives programmes for ultra-low emission biomass solid fuel technologies. Such incentive schemes can thereby be complemented by information on good practice, networking with energy auditors, installers and chimneysweepers, education, training as well as public procurement rules on MS and local/regional level Promotion and marketing activities by manufacturers and installers Finally, it should not be neglected that manufacturers and installers and their associations have an important role in promoting ULD technology. 66 They could perform especially target group-oriented marketing campaigns that highlight the innovative character and the environmental benefits as well as the further advantages of new ultra low emission SCI. In combination with the policy instruments mentioned above, such marketing campaigns could have a strong impact for the market introduction of the new technologies. 66 See 64

66 Overview Based on the policy instruments suggested in Chapter for new installations, Figure 22 presents an overview of the current policy package for new SCI and the recommended shortto mid-term evolution in Step 1. Figure 22: Step 1 of the proposed policy package for new solid biomass SCI Performance!Requirements!! (ELVs!&!MEPS)! Labelling!Schemes! Performance!Requirements!! (ELVs!&!MEPS)! Labelling!Schemes! Incen>ves!and!! Informa>on!programs! Product!Standards!! EU!Level! Ecodesign!! (in!progress)! Mandatory!Energy!Label!! (in!progress)! Voluntary!Ecolabel!! (in!progress)! Member!State!(MS)!Level! Implemented!in!some! Member!States! Standardisa>on!process!(EN)! Bench!test!@!! Nominal!(and!part!load)!!! No!change! PM!emission!level!on!label! and!product!fiche!! Ecolabel!for!room!heaters! Not!necessary!anymore! New!criteria!based!on!new! EU!product!informa>on! New!classes!for!boilers!and! introduc>on!of!! classes!for!room!heaters! Source: Wuppertal Institute (2014) 65

67 Step 2: Addressing Real Life Emissions Revision of product and test standards As already mentioned in Chapter 3 emissions are different in reality than those measured according to the current product type testing approaches, because operation patterns under real-life conditions are deviating from synthetic benchmarks, which are commonly performed at fixed levels like 100 % or 30 % of nominal heat output. In addition, emissions depend on the whole heating system, consisting of heating appliance, fuel, chimney and user. Therefore major revisions of product and test standards are recommended in mid- to long-term, in order to include much more realistic test conditions Indirect heaters (boilers) In order to better reflect the actual performance of biomass solid fuel boilers under more realistic operation conditions, bioenergy2020+, TFZ and further partners have developed a boiler load cycle test (bioenergy ) for an improved type testing approach. 67 The new boiler load cycle test is also performed on a test stand but not under the same stable operation conditions as described in EN 303-5, where tests are only performed at 100% and 30 % of nominal load. According to the new cycle test procedure, boilers are operated successively at several different loads during an 8-hour test, following a defined operation pattern in order to simulate the typical heating demand for domestic buildings (See Figure 23). Due to the modulated operation during the cycle test, the quality of the combustion process decreases in comparison to static operation modes and therefore also the emission performance of a boiler decreases. This is especially relevant for TSP emissions, which are usually higher when measured according to the cycle test than to the EN type test (see Figure 24). Figure 23: 8-hour boiler load cycle test sequence Source: bioenergy2020+ and TFZ (2010) Figure 24: TSP emissions based on type testing compared to the 8-hour load cycle test Source: bioenergy2020+ and TFZ (2010) 67 This approach can be compared with the new European EURO norm Driving Cycle performed for cars. 66

68 Direct heaters (local room heaters) In general, as for boilers, also for stoves and for room heaters a revision of the product standards and the respective type testing approaches is recommended in order to better assess the emission performance of the products. This should be based on research projects, like the recently started FP7 project BeReal, which aim at the development of advanced type testing procedures Update of the specific policy package for new SCI Both, for direct and indirect heaters, a major revision of the product standards, in order to better reflect the actual operation conditions, is possible and will have two important benefits: - A more realistic assessment of the product performance, especially considering the emissions - A better differentiation of ultra low emission, BAT and poor performing SCI products Thereby, the new product and test standards could also focus in particular on the healthrelevant particle fractions of PM 10 or PM , in order to allow a more specific policy development in the future, e.g. for optimised abatement technologies. As soon as the product and test standards have been updated in Step 2, and experience has been gathered with a sufficient number of boilers and stoves, all existing as well as new policies and measures of the policy package for new SCI have to be updated accordingly. 68 Current product policies are largely and generically based on dust (TSP). 67

69 Overview Based on the policy instruments suggested in Step 2 for new installations, Figure 25 presents an overview of the policy package for new SCI and the recommended mid- to longterm evolution. Figure 25: Step 2 of the proposed policy package for new solid biomass SCI Performance!Requirements!! (ELVs!&!MEPS)! Labelling!Schemes!! Ecodesign!! (in!progress)! Mandatory!Energy!Label!! (in!progress)! Voluntary!Ecolabel!! (in!progress)!!! EU!Level! Member!State!(MS)!Level! No!change! PM!emission!level!on!label! and!product!fiche!! Ecolabel!for!room!heaters! New!criteria!based!on! new!product!standards! (with!more!realis>c!test! condi>ons)!! Performance!Requirements!! (ELVs!&!MEPS)! Labelling!Schemes! Implemented!in!some! Member!States! Not!necessary!anymore! Not!necessary!anymore! Incen>ves!and!! Informa>on!programs! Product!Standards! Bench!test!@!! Nominal!(and!part!load)! Criteria!based!on!new!EU! product!informa>on! Standardisa>on!process!(EN)!!New!classes!for!boilers!and! introduc>on!of!classes!for! room!heaters! New!criteria!based!on!new! EU!Product!Standards! More!realis>c!condi>ons!! (e.g.!cycle!test!for!type! tes>ng!of!boilers)! Source: Wuppertal Institute (2014) 68

70 7.3. Policy package for existing SCI General policy package approach The performed scenario calculations in Chapter 5 highlight the need to address not only the market and new SCI, but especially also the stock of old and poor performing existing appliances, in order to achieve a faster emission reduction in the EU. Therefore, in addition to measures for new SCI (Chapter 7.2), it is recommended to introduce a supplementary and specific policy package also for existing SCI, which will accelerate the exchange of the stock compared to the autonomous replacement process induced by the product lifetime of the respective appliances. Figure 26 gives an overview of possible elements of such a policy package, which will be explained in the following subchapters. Figure 26: Policy package for existing solid biomass SCI Financial incentive programmes Information, good practice, networking with energy auditors, chimney sweepers and installers On-site inspection Mandatory replacement and retrofit requirements Operation requirements Regulation Marketing, promotion by manufacturers and installers Education, training Source: Wuppertal Institute (2014) 69

71 Regulation: Minimum performance requirements for SCI In order to remove old and poor performing SCI from the stock, the EU or Member States shall implement mandatory requirements also for existing SCI. Alternatively, the EU should at least encourage the implementation on MS level if regulatory restrictions do not allow such requirements on EU-level. For future regulations, the experiences of the implementation of the German 1.BimSchV should be taken into account, since it is so far the only national regulation of this kind in the EU: - For indirect heaters (boilers): Introduction of operation performance requirements with focus on TSP emissions as well as periodical on-site inspections, which are e.g. performed by chimney sweepers - For direct heaters (local room heaters): The regulation shall be based on type testing, but according to new or revised EN standards as described in Step 1 for new SCI (Chapter 7.2.3) Consequently, the regulation shall include general mandatory replacement and retrofit requirements for installations not complying with the regulation. As result of such policies, SCI with high emissions will be removed earlier from the stock and would be replaced by low or ultra low emission SCI, as consequence of the policy package for new SCI (Chapter 7.2). This effect would considerably accelerate the absolute emission reduction in the EU. In this context, it is also recommended to improve the usage of market and stock surveillance on EU and Member State level in order to have always access to up-to-date and reliable data for more specific regulations Regulation: Fuel quality Based on the discussion within the Mirror Group, the parameter fuel quality has been identified as one of the essential influencing factors for the emission performance of solid fuel SCI. Thus, it is proposed to include especially fuel quality - among other operation requirements - in solid fuel SCI specific regulatory measures. For this purpose, the quality of the fuel should be especially controlled and regulated at the point of sale, what is mainly of relevance for fuels, which are sold on the market in large quantities, e.g. by bulk wholesalers. In this context, a reliable certification system for the suppliers and a control mechanism for the fuel stock would be required. In case of biomass solid fuels, a significant share of the used fuel (wood logs, saw dust, wood chips) is coming from own resources of the SCI users and therefore - besides possible regulations - especially good practice rules should be applied (see 7.3.4). In general, all measures to exclude fuels of inadequate quality from the use in SCI would have an immediate and measureable positive environmental impact. Therefore, a general prohibition of the use of all solid fuels (as it can currently be observed in some areas in Europe) should not be seen as an appropriate measure, especially as clean and efficient technologies are already available on the market and even much better products have been demonstrated in the EU-ULD project. However, in this context it has also to be stressed that problems of low quality SCI and fuels are often and strongly related with economic and social circumstances as well as the availability of natural resources in the respective Member States. One approach to tackle this issue could be the implementation of measures to foster the use of low quality fuels, if at all, then only in (larger) combustion plants employing all the secondary abatement measures which are not yet suitable for SCI, so that indirectly these fuels will become unavailable for the individual households and the whole domestic heating sector Kubica, R. (2013), 2 nd Mirror Group Workshop (2013). 70

72 Information, education, training, networking and promotion In addition to the periodical chimney sweeping, for both, direct and indirect heaters, chimneysweepers shall also check the entire installation and the quality of fuel. Furthermore, for all installed SCI, actual user (mis-)behaviour is an essential parameter for the emission performance. For this purpose, extensive good practice information programs - beyond printed information at the point of sale - should be provided to the users of such products. Thereby, a training could be realized personally e.g. also by regular and official chimney sweeper visits in combination with advanced information brochures like the Low emission operation manual for chimney stove users (see Figure 27) developed by bioenergy2020+ and TFZ together with further partners (ERA-NET 2012). Figure 27: Low emission operation manual for chimney stove users Source: ERA-NET (2012) Furthermore, like with new SCI, manufacturers and installers and their associations have a strong role in promoting improvement and exchange of SCI in the stock. They could perform target group-oriented marketing campaigns that highlight the need for improvements and the innovative character, the environmental benefits as well as further advantages of exchanging existing old SCI by new ultra low emission products. 71

73 Financial incentives In order to address remaining SCI in the stock, which comply with the mandatory performance requirements for existing installations but whose performance is clearly below BAT level, additional financial incentives shall be implemented as pull mechanism towards (ultra) low emission technologies (see Figure 28). Basically, the financial incentives shall support the purchase of new ultra low emission SCI in case of voluntary early replacement 70, but retrofitting options (e.g. ESP) shall be fostered, too. Figure 28: Financial incentives as Pull mechanism Level of mandatory requirements Emission level Retrofit or Replacement Support for early replacement or retrofitting + Support for ULD SCI Very poor Poor Ecodesign ULD Source: Wuppertal Institute (2014) However, as for new appliances (see Chapter ), such measures can currently not be implemented or prescribed directly by the EU, but only by the Member States. Consequently, the examples for financial incentive schemes to replace old SCI by new ones can only be found on MS level: Example 1: Incentive for replacement of old installations (AT) For example, in Austria, the replacement of biomass boilers in biomass-districtheating systems is supported. For the replacement of boilers with a minimum age of 15 years and investment costs of more than 10,000, a support of 15 % of the investment costs is granted. Additionally, if the SCI is operated with regional biomass solid fuels, if the new boiler holds the UZ37 environmental label or if there are other parallel improvement measures for the entire heating system, an additional cumulative bonus of 5 % is granted respectively. 70 Combined with the financial incentive for the new installations (see Chapter ), customers might replace low performance SCI directly with the best performing products (e.g. ULD technologies). 72

74 Example 2: CIDD - Incentive for replacement of old installations (FR) In France, the replacement of old SCI is also supported by the CIDD (Crédit d impôt au développement durable) tax credit. It is applicable for biomass stoves and boilers fulfilling specific criteria, but in contrast to the support of the acquisition of new SCI only (see ), a higher incentive is granted, if an old existing appliance is replaced and verifiably scrapped. Example 3: Non-EU incentives for abatements systems (CH) For emission abatement systems in the context of SCI, there are currently only few measures, which are mainly realised on regional level due to local air quality issues. For example, the municipality of Wartau (CH) has implemented a scheme to equip existing SCI with abatement systems (e.g. ESPs) and grants therefore a subsidy of 1,250 per retrofit. Example 4: Voivodeship Fund for Environment Protection (PL) 71 As in the case of new SCI (see ), Poland has a quite well established and effective system for financial subsidies, including the Voivodeship Fund for Environmental Protection and Water Management (WFOŚiGW), which redistributes the financial resources gathered from environmental charges paid by pollutant emitting companies. This money is used by so called Programmes on Low Emission Abatement (PONE). Such programmes include different options for the switch from old heating systems to new ones fuelled with gas, oil or solid fuels (with high efficiency and low emissions) or support alternatively the connection of a building to a district heating system. Thereby, measures are especially focused on areas where ambient air concentrations of pollutants like PM exceed the allowed average values. Usually the results of the implementation of such programmes are evaluated afterwards in order to prove the expected system effect and to modify the approach if necessary. An important observation in the context of SCI is the fact, that the projected values are commonly achieved, if fuel quality as well as the heating system itself are subjected to a regular control and if also an appropriate informative and educational framework exists. 71 Kubica, R. (2013), 2 nd Mirror Group Workshop (2013). 73

75 8. Summary and Outlook In Chapter 7, policy options and instruments have been analysed in order to create specifically adapted policy packages for new Small Combustion Installations (SCI) to be placed on the market as well as for existing SCI in the stock. In the light of the results achieved by the new technologies (see Chapter 4 and 5), the objective is to realise the full technical emission reduction potential as far as possible. Thereby, the recommended policy package for new SCI consists of a two-step approach and aims at supplementing the current and forthcoming policies addressing SCI in Europe. The second recommended policy package for existing SCI is intended to support the replacement and retrofitting of SCI in the stock, which are characterised by high emissions and low efficiency. During the 2 nd Mirror Group Workshop (December 2013) with European policy makers and international experts, the proposed two-step approach for new SCI was considered as good general approach towards an improvement of new products to be introduced on the market. Following the Mirror Group feedback, Step 1 for new SCI should not encounter any major difficulties so that it can be achieved in short- to medium term, e.g. as soon as the Ecodesign implementation process will be accomplished. 72 In this context, the European standardisation process might require more time than the other parts of Step 1. The background is that new testing methods have to be agreed and approved especially with respect to emissions. The same comments are also valid in Step 2 for new SCI, where the development of essentially new and more realistic testing methods as well as the adaption of all relevant regulations could require more time. For such an implementation plan the development of adequate testing methods (considering real-life operation) for harmonized appliance and fuel standards as well as extensive information campaigns (especially in the new Member States) and consequently substantial financial resources would be needed. Therefore, based on the necessary research and regulatory process, Step 2 can be realised in a mid-to long-term perspective. Regarding the policy package for existing SCI there was a large consensus among the Mirror Group that the most essential approach to achieve large and rapid emission reductions in the solid fuel SCI sector is to combine measures for new SCI on the market especially with ambitious retrofit or replacement programs. The members of the Mirror Group agreed that a reliable SCI register or database on European level would be important for further measures considering old SCI and that it would be also useful to have a harmonised European approach for retrofitting or replacement of such appliances. However, the EU can currently only control if the Member States reach their general air quality targets, while the decision on concrete emission reduction measures is up to each Member State. Regarding SCI, this is also a major concern, as an increasing development of local regulations can have counterproductive effects. While the EU aims at harmonising the European single market (e.g. through Ecodesign), as result of the current EU Air Quality requirements, more and more regional policies regulating or even banning solid fuel SCI are implemented. Such differing regulations may hamper the European single market for heating products and may impose significant economic burdens for the boiler and stove industry for tests and certification due to conflicting obligations in different countries and regions. In order to tackle this issue, a better harmonisation or even completely new policy instruments on European Level would be needed. 72 Please note: Due to the still on-going Ecodesign process at the time of the finalisation of the project and this document, as well as the level of the proposed Ecodesign performance requirements, it is too early to propose further "recommendations regarding future emission limits" (as defined in the original project proposal). Regarding the possible future evolution of performance criteria for small-scale solid fuel combustion installations (SCI), please see also Chapter («Step 2»). 74

76 Finally, in the context of both policy packages for new and existing SCI, the Mirror Group identified two instruments to be most important. Accordingly, mandatory performance requirements are essential to address efficiency and emissions of heating appliances directly ( Push ) and financial incentives ( Pull ) are crucial to foster a much faster market and stock transformation. However, due to the existence of regulatory restrictions that hinder the implementation of such instruments on EU-level, in both SCI policy packages further and advanced information, promotion, networking, education and training programs remain essential in order to influence buying decisions of consumers and to reduce emissions in real-life operation by addressing user behaviour as well as the quality of fuels. Taking into account the comprehensive feedback of the Mirror Group, it can be stated that the implementation of the proposed policy packages is difficult in certain aspects, but yet feasible. Substantial resources are required but e.g. the new EU multiannual financial framework for 2014 to 2020 may provide such financing. Based on this, incentives as well as cohesion in building codes will support the new technologies and EU Structural Funds can be used to address major regional air quality issues, also in particular to support the new Member States, where economic and social aspects have to be taken into account even more specifically. However, especially in this context, it has to be stressed again that solid biomass has the potential in most parts of Europe to provide the cheapest and most easily available type of fuel for heating purposes and it is - considering the full costs - also the basis for the most economical type of all heating systems. With this in mind, the EU- UltraLowDust project demonstrated very promising technologies with ultra-low emissions for boilers and stoves, which show the way for a future biomass heating strategy in Europe. As next major step, the new technologies have to be further optimised for large-volume production and successfully introduced on the market, supported by appropriate policies. By this means, in the context of the EU air quality policies (e.g. NECD, AAQD) and renewable energy plans, ULD technologies in combination with the proposed policy packages for SCI can provide a major contribution to achieve the declared EU-wide sustainability targets (see Figure 29). Figure 29: Context of the policy packages for SCI Motivation for EU and Member States to act: AAQD, Gothenburg, NECD, REN, SCI Various other sources of air quality related emissions Policy package: Market Policy package: Stock Step 1 Step 2 Policies and measures: Retrofit or Early replacement Policies & Measures Achievement of air quality and renewable energy targets Source: Wuppertal Institute (2014) 75