Medium Combustion Plant permitting: phase II - next steps (UK)

The UK Environment Agency has just announced that it will begin accepting environmental permit applications for Medium Combustion Plant (MCPs) captured under Phase II by 31st March 2023.

MCPs captured under Phase II include those which require an environmental permit by 1st January 2024. These are existing plant i.e. those which were in operation before 20th December 2018 with a rated thermal input of 5-50MW.

It is expected that a large number of applications will be made to the Environment Agency once the application window opens. SLR recommends operators of such plant begin the process at their earliest opportunity to allow time to address any compliance issues and for their applications to be assessed prior to the deadline.

What do I need to do if my organisation operates an MCP captured under Phase II?

Obtain and maintain compliance with an environmental permit

You will need to make an application to the Environment Agency to obtain a permit.

The type of permit required will differ depending on the complexity of the site, with low risk plants benefiting from a simpler application process. Higher risk sites will be required to undertake detailed dispersion modelling.

The EA will charge a fee for determining the application.

Emission limits

The environmental permit is likely to contain emission limits that must be complied with.

Your plant may or may not be able to comply, requiring a technology switch, upgrade or abatement to be installed.

Monitor emissions

You will be required to monitor emissions from the plant at regular frequencies. Higher risk sites will need to undertake monitoring in accordance with the EA’s monitoring certification scheme, MCERTS.

MCERTS has exacting standards to ensure the reliability of the results and the health and safety of contractors.

To provide compliant sample facilities you may need to undertake improvement works to ducting, stacks and working platforms.

Energy Efficiency

Plant with a thermal input of greater than 20MW will be required to demonstrate compliance with the requirements of the Renewable Energy, Energy Efficiency and Motor Fuel Emissions Regulations 2021.

This can include undertaking cost-benefit appraisals of combined heat and power operation.

Record information regarding operation of the plant and any secondary abatement

You will be required to record information on the operation of plant and submit it electronically to the EA on an annual basis.

Regulator inspections

The EA will visit sites on a random basis to check compliance with the conditions of the environmental permit.

SLR can:

• Review existing and planned plant, and advise on the ability to comply with the forthcoming requirements;
• Undertake feasibility studies for the fitting of abatement, technology switches and provision of sampling facilities;
• Provide guidance on the need for, type of, and process for obtaining environmental permits;
• Advise on the emission limits and monitoring requirements for your plant;
• Prepare environmental permit applications;
• Undertake cost-benefit appraisals of combined heat and power operation; and
• Undertake air quality dispersion modelling