Health Impact from current Power Plants

Summary

The requester asked for a study on the health costs of emissions from Pulrose and Peel power stations, specifically regarding NOx and SOx. The Manx Utilities Authority disclosed a document titled 'Appendix 13' which estimates the annual cost of non-GHG emissions at £11.57 million and discusses the relevance of these impacts to social housing and climate justice principles.

Key Facts

• The response estimates the total annual cost damage from non-GHG emissions at £11.57 million.
• Combined Cycle Gas Turbine (CCGT) emissions account for the majority of the cost at £11.3 million.
• The Pulrose power station is located in an area primarily dedicated to social housing with low-income residents.
• The document references the Climate Change Act 2021 and its 'just transition' and 'climate justice' principles.
• Emission data for gas and diesel generators was extrapolated from limited 1-hour test periods using UK Government methodology.

Data Disclosed

• £11.57M
• £11.3M
• £282k
• 1403 t NOx
• 3.9 t SO2
• 0.9 t PM2.5
• 26 t NOx (Diesel)
• 1378 t NOx (CCGT)
• 3.8 t SO2 (CCGT)
• 0.1 t SO2 (Diesel)
• 09 Apr 2024
• 2024-07-01
• 2024-07-29
• Climate Change Act 2021

Original Request

I request the study which shows the cost to health from the emissions from Pulrose and Peel power stations, impact from NOx and SOx emissions.

Data Tables (1)

Full Response Text

TRANSITION ODM/003 – APPENDIX 13

09 Apr 2024

1 APPENDIX 13 – PUBLIC HEALTH IMPLICATIONS OF CURRENT NON-GHG EMISSIONS

BACKGROUND

The Climate Change Act 2021 (the Act) created statutory duties for public bodies (including Manx Utilities) as follows:

(1) A public body, in performing its duties, must act in the way that it considers best to contribute to —
(a) the meeting of the net zero emissions target by the net zero emissions target year;
(b) the meeting of any interim target; (c) supporting the just transition principles and the climate justice principle; (d) sustainable development, including the achievement of the United Nations sustainable development goals; and
(e) protecting and enhancing biodiversity, ecosystems and ecosystem services.

(c) – (e) are referred to collectively as the ‘Fair Change’ principles.

So, while the Act is primarily concerned with the reduction of GHG emissions, the climate change duties for public bodies create a framework for decision making that is wider. This is intended to ensure that decarbonisation efforts are generally designed to maximise benefit and minimise risk/harm as opposed to simply reducing emissions ‘at any cost’.

The just transition and climate justice principles are defined in the Act as follows:

8 Just transition principles and climate justice principle

(1)
In this Act, the “just transition principles” are the principles of taking action to reduce net Isle of Man emissions of greenhouse gases in a way which — (a) supports environmentally and socially sustainable jobs;
(b) supports low-carbon investment and infrastructure;
(c) develops and maintains understanding and acceptance, so far as is reasonably practicable, through engagement with —
(i) workers, trade unions, communities, non-governmental organisations, representatives of the interests of business and industry; and
(ii) such other persons as the Council of Ministers considers appropriate;
(d) creates decent, fair and high-value work in a way that supports the overall economy and mitigates, where possible, negative effects on the workforce; and
(e) contributes to resource-efficient and sustainable economic approaches which help to address inequality and poverty. (2) In this Act, the “climate justice principle” is the principle of taking action to reduce global emissions of greenhouse gases and to adapt to the effects of climate change in ways which — (a) support the people who are most affected by climate change but who have done the least to cause it and are the least equipped to adapt to its effects; and
TRANSITION ODM/003 – APPENDIX 13

09 Apr 2024

2 (b) help to address inequality.

Both of these principles are relevant to the ODM on Firm Capacity. In terms of non-GHG public health impacts (air pollution) the climate justice principle and the following phrase from the just transition principle is of particular note: “contributes to resource-efficient and sustainable economic approaches which help to address inequality and poverty.”

To understand the relevance of subsection 1(a) of the climate justice principle “support the people who are most affected by climate change but who have done the least to cause it and are the least equipped to adapt to its effects”, it is important to note that individual emissions very typically inversely correlate with income i.e. richer people tend to have higher emissions and poorer people tend to have lower emissions. Sub-section (b) requires decision makers and policy developers to consider existing inequalities.

This is relevant in this case because the Pulrose power station is located in an area primarily dedicated to social housing, the residents of which are typically low income. Improvements in air quality not only have a direct health benefit to local people but a long term financial benefit to government, by reducing health care spending. Exploring options for alternative generation therefore provides an opportunity to ‘help address inequality’ – for example, through the type of generation plant employed, the measures taken to mitigate air pollution and/or the location of the facility. If possible, the outcome should improve air quality or, at least, include mitigation measures to ensure that it is not worse.

ESTIMATING IMPACT OF EMISSIONS

The UK Government use the follow methodology for assessing the cost (or saving from abatement) of air quality changes: https://www.gov.uk/government/publications/assess-the-impact-of-air- quality/air-quality-appraisal-damage-cost-guidance

A table from the guidance, which attributes a cost value in (£/t) to each pollutant is shown below:

Some air pollution testing data is available for the gas and diesel generators but is limited to 1 hour test periods. In order to assess emissions over a year using the UK cost methodology, this has been multiplied by the estimated operating durations for each.

TRANSITION ODM/003 – APPENDIX 13

09 Apr 2024

3 Generating Equipment Emissions per Annum1 NOx (t) SO2 (t) PM2.5 (t) COST DAMAGE ESTIMATE (£) Diesel Generators 26 0.1 0.9 £282k CCGT 1378 3.8 £11.3M TOTAL 1403 3.9 0.9 £11.57M

RELEVANCE OF DECARBONISATION OF ELECTRICITY SECTOR TO JUST TRANSITION

The list of potential options provided within this Operational Decision Making exercise for delivering the 2030 target, includes approaches that would clearly reduce air pollution, particularly in the Pulrose and Peel locations, as follows:

Interconnector
Offers an improvement compared with the counter factual. A second interconnector would not negatively impact air quality on the Island. It could be argued that air quality would be affected at the location of generation e.g. in the UK. Considering that the UK already have proportionally more renewables on their network than the Isle of Man, it is likely that this impact would still be less than it would be at location of generation here i.e. an improvement overall but smaller than if the technology did not impact air quality at all.

Battery Storage
Offers an improvement compared with the counter factual. Would not negatively impact air quality on the Island.

DSR Offers an improvement compared with the counter factual. Would not negatively impact air quality on the Island.

Biofuel dispatchable
Offers a limited improvement compared with the counter factual. Biofuels, despite being highly preferable in terms of GHGs, produce only slightly less non-GHG air pollutants (egg. particulates, sulphur dioxide) than fossil fuels. For this option mitigation measures should be considered e.g. scrubbers, location, minimising use.

Connection to renewables Offers an improvement compared with the counter factual. Would not negatively impact air quality on the Island.

CONCLUSIONS

In this paper, no commentary has been made on the air quality impacts of manufacturing each different technology or the disposal. If manufacture or disposal of any of the available options is known/found to be significantly more harmful than another then this would be relevant but information is currently limited.

1 Assumptions: Diesel Generators (x MWh per year), CCGT (x MWh per year) – note that the steam turbine running hours has been excluded from the calculations TRANSITION ODM/003 – APPENDIX 13

09 Apr 2024

4 It is important, however, to consider disposal as this will be a live issue in a predetermined amount of time (i.e. the known life span of the technology) and so should not be overlooked at this stage.
In the context of the just transition and climate justice principles, air quality is not the only consideration. The potential for local employment, the cost of electricity, the potential demand on local land to produce biofuels etc. should all be taken into consideration.

Essentially, the goal is not just to decarbonise but to do so in a way that enhances economic, social and environmental sustainability. There may be no ‘perfect’ solution and there may be ‘trade-offs’, which is why the Act states that a public body must “must act in the way that it considers best to contribute to [the duties]” rather than the way that is objectively best, which may be almost impossible to determine when considerations such as cost, security of supply etc. are also necessary considerations.

Climate Change Transformation Team, DEFA
Mar 2024

Manx Utilities PO Box 177, Douglas Isle of Man, IM99 1PS

e: enquiries@manxutilities.im t: 01624 687687 www.manxutilities.im

Our ref: 3951913 25 July 2024

Dear ###

We write further to your clarified request, received 4 July 2024, which is now a valid request for information held and states:

"I request the study which shows the cost to health from the emissions from Pulrose and Peel power stations, impact from NOx and SOx emissions."

Our response to your request is as follows:

We do not hold the information requested that shows the cost to health from the emissions from Pulrose and Peel power stations, impact from NOx and SOx emissions independently. However, to assist we have attached a paper that was written on Manx Utilities behalf by the Climate Change Transformation Team (DEFA) which shows the annual estimated cost damage and emissions from the Diesel Generators and the CCGT, however further evaluation and application of data within linked reports is needed to draw a reliable conclusion.

The CCGT station accounts for approximately 99% of MU generation so is the only significant source of NOx emissions from Manx Utilities’ electricity generation. Our SOx emissions have been virtually eliminated thanks to the use of natural gas as our main fuel source and a change to using Ultra Low Sulphur Diesel as our alternative fuel source.

I have enclosed a copy of the information that is being released to you.

Please quote the reference number 3951913 in any future communications.

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I will now close your request as of this date.