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Kieran Laxen - Medium Combustion Plant: Planning impacts vs permitting risk


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Kieran Laxen spoke at the IAQM AGM 2017 on the Medium Combustion Plant, looking at the planning impacts vs the permitting risk.

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Kieran Laxen - Medium Combustion Plant: Planning impacts vs permitting risk

  1. 1. Medium Combustion Plant (MCP): planning impacts vs permitting risk Kieran Laxen
  2. 2. What we know
  3. 3. Planning vs Permitting
  4. 4. Permitting risk Benefit of operation Costs (£) Limit exceedences Tech. Photo: The regulations include: “(7) When assessing whether the operation of a medium combustion plant or a specified generator may have significant negative effects on human beings or the environment, the regulator must consider only its emissions to air.”.
  5. 5. Planning Photos: • Needs to consider full impacts. • An AQAP could specify no new MCPs or only MCPs with very low emissions. The AQAP could also impose lower emission limits for MCPs than those set out in the MCPD.
  6. 6. IAQM
  7. 7. ~5MW Emergency generator (2MW output) 9.2 kg/kWhout (1200 mg/Nm3 @15%) 5.13 18.5 49 0.92 Exempt from emissions - Madame Tussauds / Uni of Westminster ~1MW Emergency generator (0.4MW output) 9.2 kg/kWhout (1200 mg/Nm3 @15%) 1.04 3.7 49 0.19 Exempt from limits 5MW Natural gas generator 95 mg/Nm3 @ 15%O2 0.39 1.4 3000 4.21 5MW Diesel Generator 190 mg/Nm3 @ 15%O2 0.82 3.0 250 0.74 MCP vs Marylebone Road Plant Emission concentration Emission rate (g/s) Emission rate (g/hr) Annual use (hrs) Emission rate (tonnes/annum) Notes 1MW CHP – NG 250 mg/Nm3 @ 5%O2 0.08 0.3 499 0.14 Exempt from limits. In London GLA SPD applies 10MW CHP - natural gas 95 mg/Nm3 @ 15%O2 0.79 2.8 8000 22.75 2016 NO2 – 89.1 ug/m3 (Background 45.8 ug/m3) 100m of Marylebone Road LAEI: 58,336 AADT (6.8% HDV) = 1.7 tonnes of NOx /annum using EFT7 2016 factors 20kph
  8. 8. Emergency Backup Generators Photos:
  9. 9. Things to note about MCPD • Banks of <1MW plant are excluded • Permit variations may not consider full impacts • MCP could stifle development • No significance of effects considers in permitting • Not all plant will require modelling (very few in fact) • No BAT as part of MCPD • Many plant will be exempt from the emission limits • Impacts on AQMAs may not be considered • Monitoring to ensure compliance is in frequent. Every few years. So could have huge impacts without knowing. • Horizontal flues often proposed but not modelled • Backup generators which are exempt can be huge and dirty • We can’t rely on the Permitting to protect us from AQ impacts. All impacts must be considered at a planning stage!
  10. 10. Head Office 23 Coldharbour Road, Bristol BS6 7JT Tel: 0117 974 1086 London Office 1 Burwood Place, London W2 2UT Tel/Fax: 0203 873 4780