Environment Agency Methane Action Plan 2024 to 2026

Question 1

1. Introduction

Accepted Answer

Methane emissions contribute to climate change, poor air quality and low-level ozone formation. Cutting methane emissions is one of the most effective ways to reduce near-term global warming. The UN Environment Programme’s (UNEP) Global Methane Assessment states a 45% reduction by 2030 would avoid nearly 0.3°C of warming by 2045.

The UK government has committed to reaching net zero emissions by 2050. In 2022 the UK signed the Global Methane Pledge to collectively reduce global methane emissions by at least 30% by 2030 compared to 2020 levels. In 2023 the COP28 agreement called on parties to accelerate and substantially reduce non-carbon-dioxide emissions globally especially methane emissions by 2030. The UK Methane Memorandum details how reductions have been made since 1990 and what is being done to secure further progress.

Methane represented 14% of total UK greenhouse gas (GHG) emissions in 2022, with the agriculture, waste and fuel supply sectors contributing around 49%, 30% and 8% to that total respectively (Department for Energy Security and Net Zero (DESNZ), 2024 ). Since 1990 reported UK methane emissions dropped by over 62% (DESNZ, 2024). But we still need to secure even greater reductions and improve the data to better quantify and understand emissions more broadly.

The Environment Agency has an important regulatory role in reducing methane emissions in England. Our Methane Action Plan sets out how we will reduce methane emissions in England. We will use our powers as an environmental regulator and share knowledge and good practice to reduce methane emissions in the UK and internationally.

This plan has 3 main objectives:

improve the data of sectors we regulate to support better decisions and targeted action by improving how methane is measured, monitored, reported and modelled
maximise the effectiveness of our regulation to enable and encourage operators to reduce methane emissions and maximise utilisation efficiency:
- reduce and where possible prevent emissions from sectors we regulate for methane losses, such as landfill sites, and anaerobic digestors operating under Environmental Permitting Regulations (EPR)
- continue to provide technical assistance to policy makers in government to help shape future regulation to deliver further reductions in methane emissions
work with external partners to share knowledge to improve our collective understanding of how to reduce methane, measuring standards and monitoring approaches

Question 2

2. Improve the data

Accepted Answer

By improving how methane is measured, monitored, reported and modelled we will make better decisions and better target our action.

2.1 Improve data

We are working with relevant industry sectors, including water, waste and farming, to improve methane emissions data and improve on default emission factors and modelling for the UK’s GHG Inventory. These include sector specific organisations such as the Anaerobic Digestion and Bioresources Association (ADBA), Ofwat, UK Water Industry Research and Water UK, Environmental Services Association (ESA) and Fuels Industry UK.

We are improving our internal pollution inventory electronic data capture system by supporting online submission and automation of data collection – review guidance, thresholds, reporting requirements and practice (for point source and fugitive releases) to improve data quality for use in the UK GHG Inventory.

National database – we will create a national database to hold emissions data from the industrial activities we regulate to enable better forecasts and insights into trends and to measure the effectiveness of our regulation.

Update emissions factors – through the GHG Inventory Improvement Programme, we will support government as necessary to update default values where knowledge and standards have improved to ensure our internal data collection system and UK GHG Inventory are as accurate as possible, and future savings are better accounted for.

Quality assurance – we will increase support for our local area teams to prioritise achieving good quality data, monitoring standards, process controls and guidance.

2.2 Monitoring and modelling standards

Monitoring equipment – we will utilise techniques such as Optical Gas Imaging (OGI) equipment and quantification equipment for sites that we regulate for methane emissions, to raise awareness of emissions so that operators can detect and act.

Best practice – we are working with others to support the development of methane monitoring and quantification technical specification and standards; and to evaluate opportunities to develop better intelligence, including developments in new technology, novel methods such as using satellite imagery, and international best practice.

Landfill whole site measurements – we are developing and testing new methods for quantifying fugitive emissions from operational landfills using a whole site approach to inform improvements in landfill gas recovery and utilisation.

Support the development of new modelling techniques where opportunities arise.

Question 3

3. Maximise the effectiveness of our regulation

Accepted Answer

Maximising the effectiveness of our regulation will enable and encourage operators to reduce methane emissions efficiently.

3.1 Reduce emissions from sectors we regulate for methane

Make methane a priority pollutant

Air quality (AQ) and environmental damage costs – we are commissioning work to develop an alternative approach to assessing impacts from releases of methane in the absence of any AQ Environment Assessment Level, including as part of a wider approach to assessing the impact of climate change on human health. We will update staff guidance to reflect good practice on managing methane across sectors and agree levels of compliance and impact. Combined, this would inform the case for improving how we classify and describe incidents involving methane releases.

Landfill improvement programme – we are reviewing gas management systems to inform the most effective options for driving improvements to emissions.

Anaerobic digestion (AD) improvement programme – we are reviewing the leak detection and repair (LDAR) reports to develop consistent reporting requirements from the sector. We will collate the data to estimate losses and drive improvements. LDAR requirements are also being added to environmental permits as part of our permit review programmes. We will keep appropriate measures relevant in assessing this data and seek improvements as evidence presents.

Progressively issue new and modified permits to ensure Best Available Techniques (BAT) are adopted for around 120 anaerobic digestion (AD) installations used to treat sewage sludge currently being operated by water companies.

Apply waste gas management hierarchy to gas – we will work to embed across sectors to ensure waste gas is eliminated, utilised, minimised, or abated. This includes properly designed gas management contingency systems, using low-calorific flares when commissioning biogas sites and on landfills (see the landfill methane oxidation techniques report).

Update best available techniques (BAT) and other best practice initiatives

Prepare case and review opportunities for use of UK BAT Conclusions, to further reduce methane emissions, including:

LDAR – develop the BAT for LDAR based on the work of the fugitive emissions strategy and seek roll out to high priority sectors and adjust where needed for specific sectors via relevant tranches (for example landfill)
BAT for gas to grid – develop BAT with Health and Safety Executive (HSE) on remote grid injection stations covering current and emerging gas clean up technology
Methane slip – review approaches for preventing or minimising methane slip from storage, combustion engines running on methane and slip from gas upgrade stacks by working with international bodies, devolved administrations, sector group and trade bodies and through BAT

Review all permits to ensure BAT are consistent for installations and appropriate measures for waste operations are up to date across sectors where appropriate via permit review. Prioritise permit reviews based on greatest impact for emission savings.

Encourage improvements across industry in design of equipment and assets for example standards, certification, and maintenance supported by better data.

3.2 Support reduction of emissions from sectors we regulate, but not currently for methane

The following sectors contribute significant methane emissions. Although they are not currently regulated for methane, we are working with them to reduce emissions through their compliance with other existing regulatory requirements.

Water Quality EPR and BAT

Municipal sludge treatment by water companies typically utilises AD as a treatment technique. There are around 120 such facilities in England and these will be permitted as installations by March 2025. We are working with water companies to ensure this happens. Once permitted then BAT will apply, and we can regulate to ensure compliance with requirements such as preventing or reducing fugitive emissions by covering open post-digestion storage (with collection and use of currently fugitive biogas) and requiring LDAR.

Agriculture

We are:

publishing a standard rules permit for methane capture from slurry stores, and gas upgrading plant to enable adoption of innovative farm scale methane capture plant
engaging with unregulated industries to lower emissions through voluntary schemes for example industry codes of practice

3.3 Support areas we do not currently regulate

We are using our existing relationships to share evidence and information and are signposting other sectors to support to help them reduce their emissions.

Anaerobic digestion processes that we do not regulate

We are engaging with the AD industry trade bodies and look to widen this engagement to involve other interested parties for example supermarkets. Our engagement is targeted at evidence on incidents, case studies and so on in support of Defra policy consideration of the scope of EPR across the AD sector.

We will engage innovative industry and universities on, for example, methane capture on farms and hydrogen conversion on AD plants converting biomethane to hydrogen.

Question 4

4. Work with external partners and other countries

Accepted Answer

Working with external partners and other countries will allow us to share knowledge to help improve our collective understanding of how to enable methane reduction.

We will work with:

government, in particular with Defra and DESNZ, to ensure they support our approach to methane across all sectors and to continue exploring ways to reduce methane losses further. Examples include working with government to maximise landfill gas capture, destruction and utilisation, including in the absence of Renewables Obligations Certificates financial support for exported electricity from 2027, and on Defra’s commitment to the near elimination of biodegradable municipal waste being sent to landfill in England from 2028
other regulators to support consistent approach to methane and how GHGs are effectively monitored, regulated and reduced. For example Ofwat, Ofgem, HSE, North Sea Transition Authority, Natural England
academia, professional institutes and innovative industry to share knowledge and secure further funding to support work on methane emissions. For example National Physical Laboratory, Chartered Institute of Water and Environmental Management, Chartered Institute of Waste Management, ADAS
health agencies and practitioners to link human health and wellbeing to methane and related climate change. For example the UK Health Security Agency and the Office for Health Improvement and Disparities
trade associations and NGOs to help increase focus, awareness of issues surrounding methane releases, and deliver targets in industry. For example NFU, Water UK, ADBA, ESA, Fuels Industry UK, Climate Change Committee
international partners and initiatives to share knowledge. For example the Global Methane Pledge, International Energy Agency, Organization for Economic Cooperation and Development, European Union Network for the Implementation and Enforcement of Environmental Law and European Industrial Emissions Directive (IED) and BAT colleagues. The Gothenburg Protocol requires us to maintain a database on BAT and share information with other signatories. We will also work with other nations’ environment protection agencies to share knowledge, including in the UK devolved administrations (Scottish Environment Protection Agency, Natural Resources Wales, Northern Ireland Environment Agency) and USA Environment Protection Agency

Question 5

5. Overview of Environment Agency powers to regulate methane emissions across sectors

Accepted Answer

We regulate certain aspects of industry emitting methane:

landfill gas
permitted AD
fossil fuel sectors – including onshore oil and gas exploration and production sites, national transmission system gas compressor stations, oil and gas refineries, oil and gas storage

We do not regulate methane emissions from:

5.1 Environmental Permitting Regulations (EPR)

Our main tool for regulating methane is using EPR. Under EPR we have a duty to limit pollutants emitted at significant quantities, including methane. We can develop evidence to enable emission limit values (ELVs), or alternatively use equivalent parameters or technical measures to achieve the same outcome.

Regulation is generally by requiring use of appropriate measures to reduce, collect and manage emissions under BAT. BAT is the basis for setting permit conditions, which include an analysis of what is economically and technically viable, taking into consideration the costs and advantages. To date we have not routinely set methane ELVs. New environmental standards for UK industry are driven by the UK BAT process. On behalf of UK government, we host the UK BAT team. We are closely engaged with developing BAT through participation in technical working groups. We are also responsible for implementing the BAT standards in England through permit reviews. This is likely to be one of our main opportunities for improving our regulation on preventing or minimising methane emissions by incorporating standards on methane emissions, leak detection and repair into UK BAT conclusions.

For operations where BAT is not available or applicable, we identify ’appropriate measures’ as a surrogate approach. This approach allows us to be flexible in our requirements and can cover ELVs, leak detection and repair requirements and enhanced gas management techniques.

Some permits require monitoring and reporting of methane emissions, where relevant. Our main source of emissions data is our internal annual data collection system, known as the pollution inventory, which feeds into Defra reporting requirements under the National Atmospheric Emissions Inventory and Greenhouse Gas Inventory.

5.2 Control of Major Accident Hazard (COMAH)

Methane is regulated as a highly flammable gas and so comes under COMAH. This is more from a safety angle to prevent accidents but includes leak detection and repairs. We are joint competent authority with HSE and lead on environmental matters. There are de-minimus limits on the thresholds, however it is considered an aggregated hazard.

5.3 Air quality standards

Methane does not have an air quality standard and it is not currently included in the National Emissions Ceiling Regulations. Therefore, there are currently limited targets to drive setting of ELVs in permits. We do have a strong role in managing NOx (nitrogen oxides) emissions from combustion of methane. UK BAT may offer an opportunity to expand those controls.

5.4 UK Emissions Trading Scheme (ETS)

We are not currently required by the UK Emissions Trading Scheme to regulate methane, as the UK ETS caps carbon dioxide equivalent emissions but does not cover methane. In 2022, the UK ETS Authority consulted on proposals to further develop the ETS. The Authority recognise that expanding UK ETS coverage of the upstream oil and gas sector provides an additional driver for greenhouse gas reduction across the industry, particularly for methane emissions. There will be a further consultation on the inclusion of methane emissions from the upstream oil and gas sector in the UK ETS.

Question 6

6. Glossary

Accepted Answer

6.1 Best available techniques (BAT)

The available techniques which are the best for preventing or minimising emissions and impacts on the environment. ‘Techniques’ include both the technology used and the way the installation is designed, built, maintained, operated and decommissioned.

6.2 Emissions factors

Emission estimates are usually calculated by applying an emission factor to an appropriate activity statistic. Emission factors are generally derived from measurements made on several sources representative of a particular emission sector. The emission factor database contains those used in the UK National Atmospheric Emissions Inventory.

6.3 Emission limit values

Legally binding parameters that must not be exceeded. Limit values are set for individual pollutants. They are made up of a concentration value, an averaging time over which it is to be measured, the number of exceedances allowed per year, if any, and a date by which it must be achieved. Some pollutants have more than one limit value covering different endpoints or averaging times.

6.4 Emissions Trading Scheme (UK ETS)

Established by the 4 administrations of the UK, the members of the UK ETS Authority, the scheme aims to increase the climate ambition of the UK’s carbon pricing policy, while mitigating the risk of carbon leakage through free allowances. The UK ETS will promote cost-effective decarbonisation, allowing businesses to cut carbon emissions where it is cheapest to do so.

6.5 Environmental Assessment Levels (EALs)

Used by the Environment Agency to judge the acceptability of proposed emissions to air from industrial sites, and their relative contribution to the environment. EALs represent a pollutant concentration in ambient air at which no significant risks to human health are expected.

6.6 Environmental Permitting (England and Wales) Regulations 2016 (EPR)

EPR requires operators of ‘regulated facilities’ to obtain a permit or to register some activities, which would otherwise require permits, as ‘exempt facilities’. In this way EPR provides for ongoing supervision by regulators of activities which could harm the environment. EPR covers facilities previously regulated under a range of other, separate legislation. It has also been used to transpose many EU Directives into domestic law. It brings these facilities together under a single, streamlined environmental permitting and compliance framework.

6.7 Fugitive emissions

Originate from closed processes through pressurised equipment components and have the potential to emit polluting compounds to air such as methane. Fugitive emissions escape through a point of seal within the component that has failed, or via the use of pressure release valves. Therefore, these releases are unintentional which can be challenging to control and regulate.

6.8 UK Greenhouse Gas Inventory

Contains estimates of all greenhouse gas emissions by sources and removals by sinks from 1990 to the latest available year of reporting. The inventory includes the 7 greenhouse gases that the UK is required to report internationally. These are:

carbon dioxide
methane
nitrous oxide
hydrofluorocarbons
perfluorocarbons
sulphur hexafluoride
nitrogen trifluoride

The Greenhouse Gas Inventory forms part of the UK’s National Atmospheric Emissions Inventory (NAEI).

6.9 Gothenburg Protocol

Established to address pollutants that cause acidification and ground-level ozone the protocol sets national emission reduction targets.

6.10 Methane slip

The escape of unused or uncombusted methane.

6.11 National Atmospheric Emissions Inventory (NAEI)

Estimates annual pollutant emissions from 1970 to the most current publication year for most pollutants. To deliver these estimates, the NAEI team collect and analyse information from a wide range of sources, from national energy statistics to data collected from individual industrial plants.

6.12 National Emissions Ceilings Regulations

The regulations set national emission reduction commitments for Member States and the EU for nitrogen oxides, non-methane volatile organic compounds, sulphur dioxide, ammonia and fine particulate matter.

6.13 Optical gas imaging (OGI)

Uses thermal or infrared cameras to picture gas, including methane.

6.14 Ozone formation

Ozone (O3) is a gas which is damaging to human health and can trigger inflammation of the respiratory tract, eyes, nose and throat as well as asthma attacks. In addition, ozone can have adverse effects on the environment through oxidative damage to vegetation including crops. Ozone can also react with other chemicals in the air to form smog. In contrast to many air pollutants measured in the UK, there are no major emission sources of ozone itself. The vast majority of ozone is instead formed in the air from reactions between other pollutants. For example, non-methane organic volatile compounds can photochemically react with other air pollutants outdoors in the presence of sunlight (via ultraviolet radiation) to produce ground-level ozone. Similar reactions can occur with nitrogen oxides.

6.15 Pollution Inventory Electronic Data Capture (PIEDC)

The Environment Agency’s PIEDC system provides information about the releases and transfers of substances from the industrial activities we regulate.

6.16 Renewables Obligations Certificates

ROCs set suppliers’ obligations under the Renewables Obligation, which requires licensed electricity suppliers to source a proportion of the electricity they supply to UK customers from renewable sources.

6.17 Standard rules permit

An option where the environmental risks from a specific discrete activity are known. Where multiple interconnected activities take place the risk increases, meaning that the generic risk assessments no longer apply, and a standard rules permit is not appropriate.

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