Last March 27, CNA Emilia-Romagna wrote a letter to the Ass to express our Association’s concern regarding the implications of article 22 of the technical implementation standards of PAIR 2030 (Regional Integrated Air Plan), which establishes a ban on installing new biomass generators for civil use in the regional territory with a performance class lower than 5 stars; without hiding the disappointment at the Region’s decision to reject the observation presented by the Regional Entrepreneurship Roundtable, which would have allowed the extension of the installation to include 4-star generators.
CNA understands the concerns relating to PM 10 emissions and the importance of reducing the environmental impact, but believes that a fairer balance between the need to protect the environment and that of supporting local economic activities. With the entry into force of the provision on 6 February 2024, without any transitional period, considerable difficulties arose in the activity of companies and in the disposal of devices in warehouses.
Furthermore, it is worrying that neighboring regions do not apply the same restrictions, creating a disincentive to the adoption of environmental measures in our region. It should also be added that the differences in emissions between 4- and 5-star generators may not be significant enough to justify such a strict restriction.
On 23 May 2024, the region sent an explanatory circular confirming that PAIR 2030 provides for a ban on installing new biomass heat generators for civil use with an emission performance class lower than “5 stars” throughout the regional territory. Recalling in particular that the emission performance of the systems is defined, in general, by Ministerial Decree 186/2017 (Regulation regulating the requirements, procedures and skills for the issuing of a certification of heat generators powered by solid biomass fuels) and the parameters to which reference must be made for the purposes of exclusion from the ban referred to in Article 22, paragraph 1 are those relating to primary particulate matter (PP) and total organic compounds (TOC), produced by the various types of 5-star generators.
In conclusion therefore, in line with the objectives set by PAIR 2030, they are to be considered excluded from the application of the prohibition referred to in article 22, paragraph 1, the systems that respect the “5 star” emission performance levels of PP and COT indicated in the Table below even if they can be classified as “4 stars”with reference to other parameters.
