Date: August 2, 2019
Author: KiWi Power

The right side of the law

The Medium Combustion Plant Directive (MCPD) will have a dramatic impact on demand side response. Jack Christie explains how businesses can stay on the right side of the law

New legislation to improve air quality and reduce harmful emissions from medium combustion plant affects tens of thousands of businesses across the UK but many still have little idea of what they need to do or by when in order to comply. Without appropriate action businesses could be at risk of breaking the law and find themselves facing enforcement action, including financial penalties.

The Medium Combustion Plant Directive (MCPD) was introduced by the EU in an effort to reduce pollution and improve air quality.  The Directive came into force on the 24th January 2018 and is designed to curb emissions from smaller combustion plant that hasn’t previously been subjected to the Large Combustion Plant Directive and Industrial Emissions Directive.  It affects any plant with a thermal input between 1 and 50MW, including diesel generators, CHPs and boilers.

In addition to the MCPD, the governments of England and Wales have gone a step further and introduced Specified Generator Controls (SGC) which require certain types of plant to comply with stricter emissions limits in a tighter timescale. These affect an estimated 30,000 businesses in total. The regulations are complex and introduce different tranches of generation plant which must comply in different timeframes according to their emissions and operating hours.

The regulation is designed to directly tackle some of the most damaging pollutants, including Nitrogen Oxide (NOx), Sulphur Dioxide (SO2) and particulate matter.

The legalisation is impacting DSR participation dramatically. Any business wishing to take part in STOR or the Capacity Market from October 2019 onwards needs to comply now. Triad participation will also be affected. While some businesses may be accustomed to running their generators at peak-time throughout the Triad season, this will no longer be possible without a permit.

Tranche A sites over 5MW are able to run for up to 50 hours without a permit (until 2025) – see table above. This means they will have to use their 50 hours wisely and track their running hours to ensure they hit the Triads and comply with the legislation. This requires a steadfast regime that ensures sites are only called to respond to Triads when absolutely necessary.

Characteristics of the plant

The compliance timeframes vary according to the characteristics of the plant (type, age, size, fuel type) and its operating hours, but eventually nearly all medium combustion plant will need to meet the specified Emissions Limit Value (ELV) and receive a permit.  Diesel generators will require abatement technology to be fitted in order to achieve the ELV while CHP plant should be able to achieve it without abatement.

Permits are issued by the Environment Agency (or Scottish Environmental Protection Agency in Scotland or Natural Resources Wales in Wales).

An exemption exists for backup generators operating for on-site resilience only (up to a maximum of 50 hours over a rolling 12-month period) but this is lost if the generator enters into a Demand Side Response (DSR) programme.

The most cost-effective and fuel-efficient abatement technology is Selective Catalytic Reduction (SCR). SCR is a means of converting NOx into nitrogen and water, and can reduce NOx emissions by up to 99%. The technology is straightforward to install and can be retrofitted to different engine surroundings. Nevertheless, it is an expensive process per unit and can cost between £60-100k so it is important to examine the business case carefully and understand the cost-benefit of continued participation in DSR programmes.

Companies such as KiWi Power offer a complete MCPD service to guide businesses through the compliance process. With MCPD expertise and extensive knowledge of site generation assets they can advise on the best route to compliance and offer a comprehensive turn-key solution, working with specialist abatement, financing and permitting partners.

The MCPD is an important piece of legislation that will enable businesses to play their part in improving health and air quality across the UK. As a first step, businesses must ensure they understand how the legislation impacts them and what they must do to comply. Only then can they develop an appropriate strategy to maximise the value of these assets, demonstrate the return on investment from abatement, and meet their legal obligations.  

This article first appeared in the July/August edition of Energy in Buildings and Industry magazine.

If your organisation would like to learn more about how KiWi Power’s MCPD or Triad Management services can help please get in touch. We’d love to hear from you.