New Regulatory Position Statements released for medium combustion plant

RPS 353: Monitoring emissions from back-up generators

This new RPS allows operators to seek agreement for reduced emissions monitoring of limited operating hours generators used for backup emergency use only, where no safe or permanent means of emissions sampling is available.

This applies to sites which operate one or more MCP that are permitted to operate for on-site back-up power generation and are tested for no more than 50 hours per year.

The RPS does not allow for the:

• Avoidance of monitoring emissions from back-up generators that have a safe and permanent means of access.
• Use of this RPS to install new back-up generators without suitable monitoring access.

What we know

SLR has made further enquiries with the EA and confirmed the following in regard to RPS 353:

• The RPS currently only delays the monitoring provision for back-up generators until monitoring ports can be sensibly installed.
• The EA is in discussion with the Department for Environment, Food & Rural Affairs (DEFRA) on whether the need for monitoring of back-up generators can be removed entirely. However, if approved, this is expected to take some time to consult on, and the removal of monitoring requirements could be many years away from implementation.
• Each case for issue of the RPS will be site-specific.
• The RPS can apply to new or existing MCP but cannot be used as a means to not provide access for monitoring for MCP installed after the RPS was published, expect in outstanding circumstances, for instance where there is a particular issue with a back-up generator’s location.
• Evidence of eligibility for the RPS will not be required, unless there is a site-specific concern with emissions.

RPS 354: Operating a mobile boiler as an MCP

This RPS removes the requirement for an environmental permit where temporary steam boilers are hired as replacement for stationary boilers, and where there is no increase in operational installed capacity.

This RPS applies to all temporarily located steam and hot water boiler plant that are mobile MCP.

RPS 354 is in place while the EA develops a better environmental permitting approach for mobile boilers.

RPS 337: Using drop-in fuels in combustion plant instead of gas-oil

This RPS allows MCP permitted to run on gas oil, to use Hydrotreated Vegetable Oil (HVO) as an alternative drop-in fuel. It covers the gap for environmental permits issued prior to 1st October 2024 which do not have a condition allowing for substitute fuels to be used.

Sites who operate under this RPS will eventually see their environmental permits varied through either an operator- or EA-led permit variation to add HVO as a permitted fuel.

The HVO used must meet the EN15940 standard, and when using HVO must still meet the relevant emission limits.

It is likely that more alternative fuels will be added to this RPS in the future.

All RPS’s must be agreed with the EA prior to sites operating under the relevant RPS conditions.