Environmental Regulations for replacing Combustion Plants:
18 October 2023
Insights from Dr Sophie Archer, NFU Energy's Environmental Compliance Consultant.
In the ever-evolving landscape of renewable energy and environmental compliance, it is imperative for businesses operating Combined Heat & Power (CHP) engines to stay well-informed about the latest regulations.One set of guidelines that significantly impacts plant replacement in the UK is the Medium Combustion Plant Directive (MCPD), enforced by the Environment Agency (EA). The primary goal of the MCPD is to control emissions from combustion plants, thereby ensuring cleaner and more sustainable energy generation.
When considering the replacement of an existing plant accredited under schemes like the Renewable Heat Incentive (RHI), Renewable Obligation Certificates (ROC), or Feed-in Tariffs (FiT), it is crucial to be aware of the following environmental permit requirements:
MCPD Permit for plants over 1 MWth Input
Medium Combustion Plants (MCP) are combustion plants with an input capacity exceeding 1 MWth and must obtain an MCPD permit from the EA before commissioning. This primarily affects boilers with a capacity of 850 kW and above, ensuring strict monitoring of harmful environmental emissions.
Combined Heat and Power (CHP) Engines
Facilities utilising one or more CHP engines need to aggregate their capacities for regulatory compliance. The total capacity of on-site CHP engines must be calculated to determine whether the facility complies with Specific Generator regulations. It's essential to remember that a 450 kWe engine may exceed 1 MWth input, making it an MCP and necessitating compliance with permitting requirements sooner than expected.
Replacing CHPs with Agreements or Accreditations
CHPs with capacity market agreements or FiT accreditations obtained prior to October 2016 are categorised as Tranche A generators, exempt from permitting until January 2029. However, if these plants are entirely replaced, they lose their existing status and become new installations, subject to current MCPD requirements.
Partial replacements
Plants undergoing partial replacements costing less than 50% of a completely new plant's total cost can maintain their existing status and the associated MCPD compliance deadline. This provision allows flexibility for plant operators, allowing them to adjust their installed capacity, if necessary, thereby extending their compliance deadline by recommissioning as <5 MWth input.
Existing Plants Over 5 MWth Input
Existing combustion plants with an input capacity exceeding 5 MWth must apply for a permit by either 30 September 2023 (for low-risk permits) or 31 December 2023 (if an air quality assessment is required). This is essential to ensure compliance with MCPD Phase 2 regulatory requirements, enabling legal operation beyond 01/01/2024.
Existing Plants Under 1 MWth Input
Existing plants with an input capacity of less than 1 5 MWth, but more than 1 MWth have until 01 January 2029 to apply for an MCPD permit. Timely planning is essential to meet this deadline and ensure compliance. Boilers operating on virgin, gas, or liquid fuels that are under 1 MWth input are exempt from MCPD permitting, however some engines and generators may require a standard rule permit with the Environment Agency.
In conclusion, comprehending the MCPD and its implications for replacement plants is paramount for energy producers striving to maintain environmental compliance. Whether contemplating complete replacements or partial upgrades, navigating these regulations can be intricate. To streamline this process and adhere to environmental standards, it is advisable to collaborate closely with regulatory authorities and seek expert guidance from NFU Energy.
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