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This briefing note summarises the requirements for operators of combustion plants that fall under the Medium Combustion Plant Directive (MCDP)聽and聽Specified Generator regulations聽and gives an update of the key dates聽for complying with the regulations聽to be aware of.

Understanding the Requirements

The Medium Combustion Plant Directive (MCPD) forms part of the EU鈥檚 Clean Air Policy and fills a regulatory gap between small and large combustion plant, targeting emissions from combustion plants of between 1 and 50MWth input.

The Environmental Permitting Regulations (England and Wales) were amended in 2018 to implement the requirements of the聽MCPD.聽When transposing the requirements of the MCPD into the EPR, Defra introduced additional controls for Specified Generators (SG)s.聽In聽short, the amendments require operators to obtain and comply with the conditions of an environmental permit if they operate a MCP or聽SG, with a small number of exemptions.聽Both the MCP and SG controls are implemented by the EPR.

Specified Generators聽(SGs)聽are those聽MCPs聽that generate electricity for聽>50hrs per annum (incl. testing) or export electricity to the grid.

Large Combustion Plants聽(LCPs) with an aggregated rated thermal input capacity (MWth) over聽50MWth regulated as IED Chapter II and III plant are exempt from the requirements of the SG Controls.

碍别测听顿补迟别蝉

MCPD鈥痗ontrols apply to all聽MCP鈥痳egardless of the fuel type used, which have a rated thermal input of each unit between 1MWth and 50MWth.聽SG聽controls, unless excluded, apply to generators with a rated thermal input between 1MWth and 50MWth. You may find that your plant must comply under both the MCPD and SG requirements. If this is the聽case,聽then your plant must be permitted by the earliest relevant permitting date.聽There are聽several聽factors which vary the date which you are required to聽have your鈥疢CPD聽or SG鈥痯ermit in place.

Should I have a Permit?

In line with the MCPD聽and SG聽requirements,聽you should already have聽obtained聽a permit聽for your site聽if you are;

• Operating a new MCP;
• Operating a聽Tranche B specified generator; or
• Operating聽a聽Tranche A SG between 5-50MW and have NOx emissions above 500mg/Nm3 operating at more than 50hr per annum.

If you wish to聽commission聽a new聽MCP or聽enter into a聽new聽capacity market agreement which causes your聽plant to聽become a聽Tranche B聽SG,聽you聽are required to聽obtain聽a聽permit聽before the聽commissioning聽date.

In line with聽the EPR, the聽next聽set of permitting聽dates are for;

• Existing MCPs above 5MW, which are required to permitted by 01.01.2024; and
• Remaining Tranche A SG between 5MWth and 50MWth, which are required to permitted by 01.01.2025.

SLR can offer numerous services for the Environmental Permitting of聽your MCP or SG聽such as:

• Review your site and advise on MCP and SG status and advise on聽appropriate聽emission limits and monitoring requirements for your plant;
• Review existing and planned plant, and advise on the ability to comply with permitting requirements;
• Provide guidance on the need for, type of, and process for obtaining environmental permits;
• Prepare聽the聽environmental permit application聽for your plant;聽and
• Undertake air quality dispersion modelling聽for your plant.

If you require further information or wish to discuss how we can聽provide support聽please聽get in touch.