Regulatory Impact Assessment

Transkript

This project is co-financed by the European Union and
the Republic of Turkey
Bu Proje Avrupa Birliği ve Türkiye Cumhuriyeti
tarafından finanse edilmektedir
Technical Assistance for Better Air Quality by
Transposing the Large Combustion Plants
Directive (TR2010/0327.04-01/001)
Regulatory Impact Assessment
By Pat Swords
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Directive (TR2010/0327.04-01/001)
Contents of the Presentation:
• Why complete a Regulatory Impact Analysis
(RIA)?
• What does a RIA contain?
• Policy Options
• Assessing costs and benefits
• Public Participation
• Final RIA Report
• Next Steps?
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Directive (TR2010/0327.04-01/001)
RIA is a tool used to assess the likely effects of a
proposed new regulation or regulatory change.
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It involves a detailed analysis to ascertain
whether or not the new regulation would have
the desired impact.
It helps to identify any possible side effects or
hidden costs associated with regulation and to
quantify the likely costs of compliance on the
individual citizen or business.
It also helps to clarify the costs of enforcement
for the State.
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Directive (TR2010/0327.04-01/001)
RIA is an aid to political decision-making, not a
substitute for it.
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Instead, RIA is best used as a guide to improve the
quality of political and administrative decisionmaking, while also serving the important values of
openness, public involvement and accountability.
It is a process which prepares evidence for political
decision-makers on the advantages and
disadvantages of possible policy options by assessing
their potential impacts.
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Directive (TR2010/0327.04-01/001)
Who is affected by implementation of Turkish LCP
legislation?
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LCP operators in the electricity generating sector
LCP operators in industrial sectors, such as sugar,
etc.
Industrial and commercial consumers of electricity
Domestic consumers of electricity
Public health authorities due to the impacts
associated with respiratory illnesses, etc.
Concerned citizens in relation to environmental
issues and associated NGOs.
Directive (TR2010/0327.04-01/001)
Key analytical steps of RIA:
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What is the problem?
What are the objectives?
What are the policy options?
What are the likely economic, social and
environmental impacts?
How do the options compare?
How do the consultation and participation take
place?
Implementation, monitoring and evaluation.
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Directive (TR2010/0327.04-01/001)
Turkish By-Law on Principles and Procedures of
Drafting Legislation – RIA should include:
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Raison d'être for drafting legislation and type.
Benefit-cost analysis, cost-effectiveness analysis (impact
on budget).
Assessment of necessity for creating a new agency and
cadres (if applicable).
Analysis of impact on economy, business, social life,
environment, red-tape and administrative procedures
Participation and consultation.
Feasibility of the proposed legislation, etc.
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Directive (TR2010/0327.04-01/001)
RIA includes cost-benefit analysis.
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Cost-benefit analysis (CBA) is an analytical
technique that can be used to examine the
costs and benefits of a proposed regulation
or public policy initiative.
All of the relevant costs and benefits,
including indirect costs and benefits, are
taken into account.
A regulation / policy initiative is desirable if
the economic and social benefits are
greater than the economic and social costs.
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Directive (TR2010/0327.04-01/001)
RIAs not only define Policy Options, but frequently
also describe so-called Scenarios, each Scenario
being associated with a particular Policy Option.
Options may differ:
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by ambition levels, i.e. to what extent the
environmental aims are satisfied;
or by facilitation levels, i.e. to what extent the
affected companies are helped in form of long
transition periods, administrative simplifications or
financial support.
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Directive (TR2010/0327.04-01/001)
Data Collection:
• For the purpose of completing a cost assessment
of the implementation of the LCP Directive it is
necessary to collect data on the current
situation.
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Operational data, combustion technologies,
abatement technologies, emission levels, etc. –
all part of Questionnaire.
This is also the ‘do-nothing’ scenario.
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Directive (TR2010/0327.04-01/001)
Policy Options - Possible Scenarios to be
considered:
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Apply flexibility mechanisms utilising the
National Emission Reduction Plan / Limited Life
Derogation.
Identify older (and smaller?) LCPs which might
fall under such arrangements.
Consider significant and effective upgrades at
larger more modern plants and benefits to be
carried over by means of the National Emission
Reduction Plan arrangement to the smaller and
older plants.
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Directive (TR2010/0327.04-01/001)
considered (continued):
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Consider if exemption on ELVs for older
plants operating less than 1,500 hours per
year is applicable / could be applied to older
plants.
Consider implementation solely to comply
with Turkish LCP legislation (as related to the
LCP Directive 2001/80/EC).
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Directive (TR2010/0327.04-01/001)
considered (continued):
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Include the additional expenditure in order to
comply with Emission Limit Values in the IED and
the forthcoming BAT conclusions for the LCP
sector.
Possibilities for fuel switching – such as greater
use of low sulphur natural gas.
Possibilities for increased use, where viable, of
low emissions sources, such as nuclear, hydro,
biomass, etc.
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Directive (TR2010/0327.04-01/001)
Assessment of Benefits:
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Existing situation;
The ‘Do-Nothing’ scenario with increased levels of
power generation in addition to the existing
situation and;
The LCP ELV implementation scenarios with the
associated reduction in discharges of pollutants.
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Directive (TR2010/0327.04-01/001)
Benefits assessed on source – pathway – receptor
model:
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Directive (TR2010/0327.04-01/001)
Typical Monetary Valuation of impacts.
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Directive (TR2010/0327.04-01/001)
The direct financial costs to be assessed
with relevance to the individual LCPs
comprise:
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Capital Expenditure (CAPEX) for installation
of emissions control measures or other
related Best Available Techniques (BAT) applicable to some but not all facilities.
Operational Expenditure (OPEX) associated
with the above.
Social cost of increased electricity charges
to pay for the above CAPEX and OPEX.
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Directive (TR2010/0327.04-01/001)
Additional costs to be assessed:
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Environmental impact associated
with increased use of lime and
disposal of gypsum (an ‘external
cost’).
Financial and environmental costs
associated with some loss of LCP
efficiency; i.e. reduced power
station output.
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Directive (TR2010/0327.04-01/001)
Principle of Cost – Benefit Analysis
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Directive (TR2010/0327.04-01/001)
For the scenarios identified the results will have
to be analysed and the options ranked, based on:
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Feasibility / Practicality – can the necessary
technology be delivered in the timeframes
required.
Environmental benefit – reduction in external
costs
Financial cost – CAPEX, OPEX and timeframe over
which costs ensue
Social cost – resulting impacts from rise in price of
electricity.
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Directive (TR2010/0327.04-01/001)
Public participation will need to include:
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Identification of the stakeholders
Preparation of the necessary information
Dissemination of the information
Stakeholder review and submission of analysis /
comments
Taking due account of the public participation; a
summary of the comments received, a description of
where and why they have been incorporate or, as
the case may be, those which have not and why not.
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Directive (TR2010/0327.04-01/001)
Final RIA Report:
• According to Turkish requirements,
RIA Reports should be written in
simple and understandable language,
and normally should not exceed 30
pages.
• Additionally, all information annexes
of the report and supporting
documentation should be provided.
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Directive (TR2010/0327.04-01/001)
Next Steps?
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Identify LCPs in terms of compliance – Traffic Light
System:
• Red Significant CAPEX required
• Yellow  Nearly there
• Green Compliant
Prepare background information for significant
CAPEX; site details, technology options, schedule, etc.
Arrange half day meeting with cost estimator and site
technical / engineering to derive CAPEX estimate.
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Questions?
Directive (TR2010/0327.04-01/001)

Regulatory Impact Assessment

Transkript

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