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
• Needs to consider full
• 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.
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!
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