How we will implement the MCPD & Generator Regulations

John Henderson

Senior Advisor Fuel & Power, Environment & Business

IAQM 16 November 2017

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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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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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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Background - Generators

Energy market incentives increasing number and use of diesel generators.

Diesel generators: unregulated high emissions of NOx

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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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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

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

Timescale for implementation of MCP and Generator controls

20/12/2018New MCPs must be permitted, emissions tested within four

months and comply with Emission Limit Values (ELVs)

01/10/2019Tranche B generators must be permitted and comply with

standard permit conditions

10/01/2019Tranche A 5-50MW generators with emissions above 500mg/m3

which operate for more than 50h per annum must be permitted.

01/01/2024Existing MCPs above 5MW must be registered and test emissions

within four months of registration

01/01/2025Existing plant above 5MW must comply with ELVs

Remaining Tranche A 5-50MW generators must be permitted.

01/01/2029Existing MCPs 5MW and below must be registered and test

emissions within four months of registration

01/01/2030Existing MCPs 5MW and below must comply with ELVs

Tranche A 1-5MW generators must be permitted.

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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 & issueConsulting LAs - AQMAs

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Generator Permitting – what do we expect

Tranche B (new) – issue before 2019Standard 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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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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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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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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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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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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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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Any Questions ?