The Medium Combustion Plant Directive - Specified Generators

Medium Combustion Plant Directive

The deadline for the permitting of Tranche A 5-50 MW generators with emissions of NOx above 500mg/m3 which operate for more than 50 hours a year is the 1st October 2019.

Overview

The Environmental Permitting Regulations 2018 were published in January 2018 to transpose the requirements of the Medium Combustion Plant Directive (MCPD) and to control emissions from the operation of Specified Generators.

Specified Generators are a major source of air pollutants that may cause harm to human health and the environment. The Medium Combustion Plant Directive (MCPD) sets out rules to control emissions of sulphur dioxide (SO2), nitrogen oxides (NOx) and dust into the air.

The Specified Generator regulations also control emissions to air, primarily NOx, from generators that would not be captured by the MCPD.

Within the regulations the requirements for Medium Combustion Plants (MCPs) are set out in Schedule 25A and for Specified Generators (SGs) in Schedule 25B. The schedules include significant dates for submitting a permit application.

Specified Generators

Operators of Specified Generators that are in scope will require an environmental permit under schedule 25B of the Environmental Permitting Regulations by the relevant date. A permit is determined by the capacity, emissions and operating hours of the plant.

‘Specified Generators’ are any combustion plants which are used to generate electricity and are on a site aggregated to less than 50 MWth. Specified Generators are also divided into Tranche A and B depending on the electricity supply contract they may have.

Interpretation – Specified Generators

In Schedule 25B a “specified generator” means:

  1. A generator, other than an excluded generator, with a rated thermal input:
    1. More than or equal to 1 megawatt and less than 50 megawatts, or
    2. In the case of a generator used to meet a capacity agreement or an agreement to provide balancing services, less than 50 megawatts;
  2. Where two or more generators falling with paragraph (a) (i) or (ii) are operated:
    1. On the same site,
    2. By the same operator, and
    3. For the same purpose,

Those generators together, provided that the rated thermal input of those generators together is less than 50 megawatts; or

  1. Where two or more generators, other than excluded generators:
    1. Are operated as set out in paragraph (b) (i) to (iii), and
    2. Together have a rated thermal input more than or equal to 1 megawatt and less than 50 megawatts, even if one or more of the generators has a rated thermal input of less than 1 megawatt,

Those generators together.

Interpretation – Relevant Date

The “relevant date” in relation to a specified generator means:

  1. 1st January 2019, in the case of a Tranche B generator;
  2. 1st October 2019, in the case of a Tranche A generator with a rated thermal input greater than 5 megawatts which:
    1. Has an emission of nitrogen oxides of equal to or greater than 500mg/m3, and
    2. Operates for more than 50 hours per year;
  3. 1st January 2025, in the case of a Tranche A generator with a rated thermal input greater than 5 megawatts which:
    1. Has an emission of nitrogen oxides of less than 500mg/Nm3, or
    2. Operates for less than or equal to 50 hours per year;
  4. 1st January 2030, in the case of a Tranche A generator with a rated thermal input equal to or less than 5 megawatts.

Interpretation – Tranche A Generator

A “Tranche A Generator” means a generator:

  1. With a rated thermal input equal to or greater than 1 megawatt and less than 50 megawatt:
    1. Which came into operation before 1st December 2016,
    2. Which is the subject of a capacity agreement arising from the 2014 or 2015 capacity auctions (whether or not the generator came into operation before 1st December 2016)
    3. For which a Feed-in Tariff preliminary accreditation application was received by the Gas and Electricity Markets Authority:
      1. Before 1st December 2016
      2. With a rated thermal input of less than 1 megawatt:
        1. Which is the subject of a capacity agreement arising from the 2014, 2015 or 2016 capacity auctions (whether or not the generator came into operation before 1st December 2016)
        2. For which a Feed-in Tariff preliminary accreditation application was received by the Gas and Electricity Markets Authority before 1st December 2017
        3. Which is the subject of an agreement to provide balancing services entered into before 31st October 2017

provided that a generator ceases to be a Tranche A generator if it is the subject of a capacity agreement, or an agreement for provision of balancing services, where that agreement is entered into after 31st October 2017 and remains in force after 31st December 2018

Interpretation – Tranche B Generator

A “Tranche B generator” means any generator which is not a Tranche A generator or an excluded generator (and includes a specified generator which has ceased to be a Tranche A generator).

Specified Generators: How to apply for a permit

Operators of a Specified Generators should apply as follows:

  • Existing Local Authority (LA) permit – If your combustion plant is part of a LA permit you will need to apply for a new permit.
  • For a Specified Generator that does not have a permit there are two methods of applying for a permit:
    • Standard Rules Permit Application
    • Bespoke Permit Application
  • Or you could vary your existing permit

Standard Rules Permit (SRP) Application

The rules are based on a generic risk assessment which included air quality modelling. Operators meeting the conditions for a standard rules permit should complete the electronic application form which is available from the Environment Agency.

All completed Specified Generator SRP applications should be sent to:

mcpdapplication@environmentagency.gov.uk

It should be noted the SRPs for Tranche B Specified Generators are for sites that only have Tranche B Generators. If the site has mixed Tranche A & Tranche B Generators on site then a bespoke application is required.

The available SRPs are:

  • SR2018/1: Specified Generator, Tranche B low risk, base load operation between 0 – 5 MWth
  • SR2018/2: Specified Generator, Tranche B low risk, base load operation 0 – 2 MWth with high background NOx
  • SR2018/3: Specified Generator, Tranche B low risk, base load operation 0 – 2 MWth in Air Quality Management Areas or high ambient NOx
  • SR2018/4: Specified Generator, Tranche B low risk, 0 – 20 MWth of gas or abated diesel engines operated less than 500 hours a year
  • SR2018/5: Specified Generator, Tranche B low risk, 0 – 20 MWth of gas or abated diesel engines operated less than 1,500 hours a year
  • SR2018/6: Specified Generator, Tranche B low risk, base load operation 0 – 1.3 MWth with high background NOx
  • SR2018/7: New, low risk, stationary Medium Combustion Plant 1 < 20MWth (in operation after 20/12/2018)
  • SR2018/8: mobile plant Specified Generator, Tranche B low risk, base load operation <1 – 2 MWth
  • SR2018/9: Specified Generator, Tranche B low risk, base load operation between 0 – 0.9 MWth

Bespoke Permit Applications

If an operator is unable to meet the SRP conditions they will need to apply for a bespoke permit. They should complete Form B2.5, Form A and Form F available from the Environment Agency.

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