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Applying for an Environmental Permit

If you have an existing Medium Combustion Plant (MCP) and/or Specified Generators (SG) with a net installed thermal input of 5-50MWth, it might be time to apply for an Environmental Permit.

Jennifer Stringer

UK

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The regulations

The Environmental Permitting Regulations 2016[1], which applies in England and Wales, was amended in 2018 to introduce a new permitting system for Medium Combustion Plant (MCP) and Specified Generators (SG). This implemented the requirements of the Medium Combustion Plant Directive (MCPD)[2], an EU Directive.

The new permitting system already applies to:

  • all new MCP and SG facilities; and
  • existing SG plant with a thermal input of 5-50MWth, emissions of nitrogen oxide of 500 mg/Nm3 or more, and operating for more than 50 hours per year

It’s being rolled out to existing plants in a series of tranches, depending on the installed capacity and emissions performance.

Who will be affected in the latest tranche?

Operators of any existing standalone MCP with a net thermal input of 5-50MWth and any Tranche A[1] SG with a net thermal input of 5-50MWth, or a Tranche A SG that operates for less than 50 hours per year.

[1] A Tranche A specified generator is a generator that was in operation before 1 December 2016 or there was a contract to provide services to the national grid before 31 October 2017.

When do I need to apply?

Operators of any existing standalone MCP with a net thermal input of 5-50MWth will need a permit by 1st January 2024. The Environment Agency queue of work means it’s possible that any application submitted now isn't guaranteed to be determined by the 1st January 2024. However, it's expected that the Environment Agency would view any application submitted before the required date favourably. You need to act now and submit your application as soon as possible. 

Operators of any existing Tranche A SG with a net thermal input of 5-50MWth, or a Tranche A SG that operates for less than 50 hours per year, will need a permit by 1st January 2025. Although this is more than a year away, the application process can be lengthy. We’d advise you to start planning now in order to ensure your permit is submitted and determined on time.

What do I need to do?

There are a variety of permit options that may apply to your facility. The starting point would be to determine which one you need.

You’ll need to prepare and submit an application for a permit that includes the required information to enable the Environment Agency to determine your application and pay the correct application fee.

You should be aware that the Environment Agency has introduced revised application forms and new requirements/tools for certain permit types.

How can RPS help?

At RPS we have a team of specialists who advise and assist with obtaining environmental permits for MCP and SG facilities. We can:

  • provide advice on whether these requirements apply to your facility;
  • assist with deciding on which type of permit is required for your activity;
  • support you with the negotiations with the UK regulators and prepare and submit an application on your behalf.
  • assist you with securing an agreed position to continue operating until a permit is issued.

If you think your operation could be affected by these legislative requirements please get in contact, our team is here to help.