If your plant exceeds 1 MWth input and was commissioned after the 20 December 2018, it requires an Environmental Permit from the Environment Agency under the Medium Combustion Plant Directive (MCPD). Existing plants that were commissioned prior to December 2018 will require permitting in:
- 2025 for plants over 5 MWth input
- 2030 for plants between 1 and 5 MWth input.
When do you need a permit?
What your site combusts, and at what fuel capacity it is, determines which permit you may be applicable for, and whether it is the Environment Agency or Local Authority who regulates you. Any existing plants over 1 MWth that have had substantial refurbishments or ended up undergoing a complete replacement (whether it be due to a substantial breakdown or an accident) would then be considered a new plant upon recommissioning. This would mean that these plants would require a permit prior to the recommissioning in order to be operated legally.
There are also increasing checks by OFGEM and the Environment Agency occurring to ensure that all plants that require a permit are identified.
How long does it take to get a permit?
At present, there is a three to four month delay to have permit applications allocated to a permitting officer, and another three months after the application is Duly Made, for it to be determined and issued, if successful.
Therefore, applications need to be made at least seven months prior to any project or OFGEM deadlines!!
You must have the permit issued before you can apply for your Stage 3 RHI Tariff Guarantee (Full application).
What about upkeep?
On top of applying for a permit, it is important to maintain existing permits correctly. Your regulator is entitled to request to see all delivery paperwork on site audits, as well as copies of the exhaust gas testing reports. Therefore, it is important to have evidence that you are only burning what you permitted to, and that any extractive emissions tests demonstrate that you are operating within your permit emission limits. Any audits that find non-compliance can result in heavy fines, if not shut down of your boiler in worst cases.
In addition, for sites combusting over three tonnes per hour who are yet to apply, a Fire Prevention Plan will also be critical to ensure that self-heating and spontaneous combustion events are avoided at all costs. If you cannot convince the Environment Agency that the site is properly managed, you will not be issued a permit.
If there are any adverse events where excess emissions are released, or an accident occurs onsite, notification to an allocated regulatory officer at your local installations team must be made within 24 hours, or further penalties will apply.
If you require any assistance regarding Environmental Permitting or advice regarding ongoing permit compliance management, call us on 024 7669 8899.