Medium Combustion Plant Directive (MCPD)
To comply with the requirements of the Environmental Permitting Regulations (EPR), Schedule 25 you can now apply for a permit from the Environment Agency (EA) for the following:
- New standalone MCPs between 1-50MWth (before it is commissioned).
- Existing standalone MCPs between 5-50MWth (must be permitted by 1st January 2024).
- Tranche A and B specified generators (permitting date requirement varies).
We recommend that you make an application for standard rules and simple bespoke permits for existing standalone MCPs between 5 – 20 MWth as soon as possible to meet the regulatory requirement for a permit before the 1st January 2024.
Standard Rules (SR) Permit for New and Existing Low Risk Stationary MCPs
The EA has published a revised SR2018 No7 which will now mean it can be used for existing low risk stationary MCPs 5-20MWth in addition to new MCPs 1-20MWth.
The EA has also published a new SR2022 No9 which is for new 1-20MWth and existing 5-20MWth low risk, stationary MCP which are natural gas boilers.
To apply for a SR permit you must be able to meet the rules set out in the permit, if you cannot you need to apply for a bespoke permit.
If you already have a SR2018 No7 permit and you now want to add some existing MCPs at the same site then you should use the same application form as you would if applying for a new SR permit.
Operators who already have a SR2018 No7 permit should have received an email explaining how they will transition to the revised rule set at the end of March 2023.
Bespoke Permits for Existing Standalone MCP 5-50MWth
If you cannot meet the conditions in a standard rules permit, you must apply for a bespoke permit.
There are 2 types:
- Simple bespoke (low risk) – does not require detailed air dispersion modelling.
- Complex bespoke (high risk) – does require detailed air dispersion modelling.
The guidance has been updated so that you can assess which type of bespoke permit you must apply for and the information you will need to provide.
The air emissions risk assessment process has been updated; breaking it down into stages. Stage 1 provides a minimum screening distance to a protected habitat, if you are operating MCP outside of these distances then you can apply for a simple bespoke permit. If you are within the Stage 1 screening distances, then you should move to a Stage 2 assessment.
The Stage 2 assessment will involve using a screening tool called ‘SCAIL combustion’. It is still under development and is now delayed until the 30th June 2023.
If you wish to apply for a permit before SCAIL is available, for example you have new plant requiring a permit you can apply for a complex bespoke anytime. There will be no regulatory position to cover new MCP’s requiring a permit.
If you already have a complex bespoke permit for your new plant and you now want to add existing plant, you will need to make a variation application. Provided existing plant was included in the original air dispersion modelling report (ADMR) which was submitted during determination of that permit you may use this ADMR again when you apply to vary the permit providing there have been no changes, such as to fuel types with additional pollutant emission limits or increase in operating hours.
If existing plant was not included in the original ADMR and you cannot screen out using the air emissions risk assessment guidance, then you will need to submit another ADMR which does include both new and existing combustion plant. You may want to future proof this report to include all combustion plant on site – for example MCPs 1-5 MWth.
If you already have a bespoke permit for a specified generator and that plant will now need permitting as an existing MCP you will need to make an application to vary your permit. The type of application you need to make, the charge and the supporting information will vary depending on the circumstances:
- If your permitted plant burns natural gas or gas oil it will retain the same emission limit values in the permit, this means that we will not need to reassess any air quality emissions assessments/modelling – you should make a minor variation application.
- If the emission limit values will change when we add the MCPD requirements because you are burning a fuel which has dust and SO2 emissions, you may need to provide a revised air quality modelling report.
EA Review of MCPs, Listed as part of an Industrial Emissions Directive (IED) Permit
For existing MCP between 5-50MWth which are listed as part of an Industrial Emissions Directive (IED) permit we will carry out a review of these permits to ensure they are MCPD compliant as a minimum.
Reviews of permits in the industrial food, drink and milk and bio-waste sectors are already underway as part of a wider review programme.
Specified Generators
The EA has published a revised specified generator tool. You can now use this tool as part of an air emissions risk assessment for a bespoke application if you operate one of the following:
- Tranche B or Tranche A specified generator site, or a mix of Tranche A and B specified generator site where all Tranche A generators comply with the Tranche B requirements.
- Single or group of new or existing engines that can achieve the medium combustion plant directive and, or specified generator emission limit values.
- Specified generator or generators that have vertical stacks without cowls or caps.
- Specified generator or generators that are fuelled by natural gas or are fuelled by ultra-low sulphur diesel with secondary abatement, used for balancing and aggregated to no more than 20MWth.
