LEGISLATION
ENVIRONMENTAL REGULATIONS FOR REPLACING COMBUSTION PLANTS Insights from Dr Sophie Archer, NFU Energy’s Environmental Compliance Consultant
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n 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
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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 plants - those put into operation prior to 20 December 2018, that are over 5MWth input must have an environmental permit in place by 01 January 2024.
ENERGY MANAGER MAGAZINE • NOVEMBER/DECEMBER 2023
EXISTING PLANTS UNDER 1 MWTH INPUT Existing plants with an input capacity of less 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. 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. For support at every stage of this journey, please contact the NFU Energy team at 024 7669 6512 or via email at sales@nfuenergy.co.uk For more information, please visit www.nfuenergy.co.uk
