John Henderson of the Environment Agency presented at the IAQM AGM 2017 on the 16th November discussing how the Environment Agency will implement the Medium Combustion Plant Directive and & Generator Regulations

1. How we will implement the
MCPD & Generator
Regulations
John Henderson
Senior Advisor Fuel & Power, Environment & Business
IAQM 16 November 2017

2. What I will be talking about today
A reminder of why – MCPD & Generator regs.
The process so far
Permitting Generators
Permitting MCPs
Further stakeholder engagement
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3. Reducing air pollution saves lives, the
environment, and billions for the economy
Poor air quality (NO2 and PM 2.5) contributes to up to 50,000 premature deaths a
year.
Health costs around £30bn a year.
Fourth biggest factor in reducing life expectancy – more than smoking or road
accidents.
Affects those with chronic heart and lung conditions.
Emerging evidence of impacts on childhood lung development and foetal brain
growth.
Major impacts on agriculture and ecosystems.
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4. MCPD background
• Part of the Clean Air Package published in December 2013.
• Designed as a safety net, setting minimum emission controls for 1-50MW
combustion plants – controls apply for nitrogen oxides, sulphur dioxide and
particulates, and depend on plant type, age, size and fuel used.
• Will help improve air quality and meet new National Emission Ceilings in 2030
- providing an estimated 39% of the SO2, 17% of the NOx emission and 7% of
particulate reductions needed.
• Estimated annual average costs of £15M and benefits of £93M.
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5. Background - Generators
Energy market incentives increasing number and use
of diesel generators.
Diesel generators: unregulated high emissions of
NOx
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6. MCPD & Generator transposition process
Defra public consultation on broad approach ended
February
Defra stakeholder workshops – May to September
EA will be the regulator in England under EPR
Legal instrument and Impact Assessments to be laid
in Parliament – December
Legislation made and comes into force - January
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7. Generator controls 1
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1. Generator definition applies aggregation with no de
minimis rule; mobile plant are in scope if providing
services to the grid or connected to permanent
infrastructure; sites under 1MW are in scope only if
providing balancing services
2. Backup generators which are tested for up to 50 hours
a year are exempt and there is no restriction on when
testing takes place
3. Generators with safety roles in nuclear sites exempt
4. Tranche A generators benefit from transitional
arrangements – qualification dates for sites under 1MW
are one year later than for 1-50MW sites

8. Generator controls 2
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1. Standard permit conditions – limit of 190mg/Nm3 NOx
retained which must be achieved within 20 minutes of
operation for Tranche A and 10 minutes of operation for
Tranche B
2. Tranche A generators subject to standard permit
conditions when capacity agreements from 2014 and
2015 expire
Tranche Criteria Permitting deadline
B All 1 January 2019
A 5-50MW, >500mg/Nm3 NOx, >50hpa 1 October 2019
A Remaining 5-50MW 1 January 2025
A 0-5MW 1 January 2030

9. Timescale for implementation of MCP and Generator
controls
20/12/2018
New MCPs must be permitted, emissions tested within four
months and comply with Emission Limit Values (ELVs)
01/10/2019
Tranche B generators must be permitted and comply with
standard permit conditions
10/01/2019
Tranche A 5-50MW generators with emissions above 500mg/m3
which operate for more than 50h per annum must be permitted.
01/01/2024
Existing MCPs above 5MW must be registered and test emissions
within four months of registration
01/01/2025
Existing plant above 5MW must comply with ELVs
Remaining Tranche A 5-50MW generators must be permitted.
01/01/2029
Existing MCPs 5MW and below must be registered and test
emissions within four months of registration
01/01/2030
Existing MCPs 5MW and below must comply with ELVs
Tranche A 1-5MW generators must be permitted.
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10. Generator Permitting
Bespoke permitting based on our generic modelling
(https://www.gov.uk/guidance/air-emissions-risk-assessment-for-your-environmental-permit)
AQ modelling guidance – site specific impact
(https://www.gov.uk/guidance/environmental-permitting-air-dispersion-modelling-reports)
Technology, size of engines
Location and sensitive receptors
Characterise emissions to air - MCerts
Operational envelope – period & times
Permit determination & issue
Consulting LAs - AQMAs
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11. Generator Permitting – what do we expect
Tranche B (new) – issue before 2019
Standard Requirements – 190 mg/m3 NOx at 15%O2
SCR operable with 10 mins if necessary
No dark smoke
Modelling to demonstrate no breaches of AQ stds at sensitive
receptors – conditioned if necessary
If not put into operation before 19/12/2019 MCPD
new plant ELVs apply
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12. Generator Permitting – what do we expect
Tranche A (existing) – issue before October 2019
Modelled impact and permit limiting operations where
necessary
Exemptions from permitting
<5 WWth, <500mg/Nm3 NOx or <50hrs pa
Exemption from Standard Requirements that apply
2025 or 2030
Operational before 1/12/16 & 2013/4 CM or FiT etc.
Specified Generators
MCPD ELVs apply from 2024/5 or 2029/30
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13. MCPD Permitting: Application – Annex 1 of MCPD
Size – rated thermal input MWth
Technology
Fuel
Age of MCP & proof
Which sector
Anticipate hour pa and load
<500 hr pa ELV exemption declaration
Company registration & location of MCP
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14. MCPD operator obligations
• Ensure plant has valid permit for operation.
• Ensure compliance with applicable ELVs.
• Ensure compliance with monitoring frequency and rules.
• Keep the required data for at least 6 years and plant permit.
• Supply data when requested by the Competent Authority.
• Take the measures necessary to restore compliance with ELVs within the shortest
possible time.
• Notify the Competent Authority of events of non-compliance as set out under
National rules.
• Keep periods of start-up and shut down as short as possible.
• Notify the Competent Authority without any undue delay of planned changes to
the combustion plant which would affect the applicable ELVs.
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15. MCPD competent authority obligations
• Issue plant permits based on information supplied by the operator.
• Determine whether new combustion plants at a site should be aggregated.
• For MCPs in AQMAs consult with LAs to identify how we can safeguard local air
quality.
• Amend permits to reflect modifications to combustion plants, or if required when
reviewing information collated in compliance checks.
• Carry out compliance checks; direct operators to take action to rectify non-
compliance.
• Make available a public register with the up-to-date information on permitted MCPs –
must be on the web.
• Determine when to apply the derogations from ELVs in case of shortage of low
sulphur fuels or interruption in supply of natural gas.
• Order suspension of plant operation when a non-compliance with ELVs causes
significant degradation to air quality.
• Answer public information requests, requesting data from operators if required.
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16. Developing guidance with stakeholders
Informal process – no formal consultation – see
guidance overview discussion paper
Generator & MCPD – monitoring to follow
Permit Applications expected summer 2018
Finalise guidance spring 2018
IT based application, permit issue, Public Register &
Compliance – Plan A
Plan B is paper based
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17. MCPD some ongoing issues
Standard Rules? Another SR consultation
Bespoke where MCP is located in an AQMA
Mobile MCP permits
< 500 hr ELV exempt permits
MCPs on Part A, 1.1 & 5.4 Part Bs
Amending existing guidance – Part Bs, AD &
LF gas engines
Charging – see IA but also SRoC consultation
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18. Any Questions ?