MJAC Founded 1928 December 2016 Lynda.fawthrop@dudley.gov.uk

Technical Committee (Air Reg) Committee Members: Lynda Fawthrop lynda.fawthrop@dudley.gov.uk Ian Rathbone RathbonI@walsall.gov.uk Gerg Jambor Gergely.L.Jambor@birmingham.gov.uk Vacancies - Any interest

Brexit Defra advises: The UK remains a full member of the EU until exit negotiations are concluded All rights and obligations remain in force During this period the Government will continue to negotiate, implement and apply EU legislation The outcome of the negotiations will determine what arrangements apply in relation to EU legislation once the UK has left the EU

Pollution Prevention and Control Defra - Main Issues General Guidance Manual Environmental Permitting Regulations 2017 Incineration of wood Review of Fees & Charges Consultation -Reducing emissions from Medium Combustion Plants and Generators

Pollution Prevention and Control General Guidance Manual Keith Crane advised that this is taking longer than expected. As an interim measure it is hoped revisions of the process and sector guidance notes will be begin at the start of next year, followed by a wider general review of the guidance. Regulations EP Regs 2017 laid in Parliament on 10th October 2016, approved by both Houses of Parliament To come into force at the start of January 2017 A consolidation bringing together the 12 amendment regulations and amendments made by other legislation. The consolidation does not involve policy changes.

Incineration of Wood Waste In 2013 amendments removed an exclusion for plant burning clean wood from Schedule 1, Part 2, section 5 .1 (a)The incineration in a small waste incineration plant with an aggregate capacity of 50 kilogrammes or more per hour of the following waste—(v)wood waste with the exception of wood waste which may contain halogenated organic compounds or heavy metals as a result of treatment with wood preservatives or coatings; Update Sept 26th from Keith Crane on lack of guidance and the requirement for a full fee permit. Review of fees and charges – intend to make amendments to Article 4 of the Part B charging scheme to allow one permit/one fee for wood incineration when associated with another installation. Seeking to update PG1/12 possibly with an interim fix No date for either of these actions

Review of Fees and Charges The aim of the review is to establish if The fees and charges are set at the correct level There are ways to reduce burdens for LA regulators and/or for industry There are ways to streamline administrative processes within Government to reduce the burden on the tax payer. The consultation is part of the review and included the MJAC Risk Assessment for Part B installations The consultation sought views on: If the level of charges allow LA’s to recover costs The mechanism for setting fees and charges for LA environmental permits If the proposed Risk Methodology is an improvement on the existing scheme Reduction in inspection rates for low risk facilities (such as dry cleaners and petrol stations) Charges for IED derogations Any additional processes that could be controlled by simplified permits

Consultation on Reducing Emissions From Medium Combustion Plants and Generators to Improve Air Quality MCPD to control emissions from combustion plants 1-50MWth Will be transposed into UK law December 2017 New plants to comply by December 2018 Existing plant to comply by 2024 – 2029 depending upon size Likely to affect >30,000 plant Emission limits and periodic monitoring Rapid growth of low cost diesel generators for the energy market - emit high levels of NOx compared to other MCPs Time is of the essence to avoid air quality problems MCPD not sufficient to tackle emissions

MCP Approach A permit will be required to operate a MCP between 1 and 50 MWth All MCPs operating for >500 hours will need to comply with emission limits (limited exemptions) All MCPs firing on solid fuel will be required to comply with emission limits Emission limits will apply to all new plant from Dec 2018 From January 2025 for existing >5MWth From January 2030 for existing between 1 and 5 MWth

MCP Consultation Questions Flexibilities regarding ELVs due to diverse nature of MCP’s Exemption on hours of use, rolling 3 and 5 year averages Higher ELVs for certain plants Non road mobile machinery , what is included What requirements will apply to biomass Compliance checks Scheduled checks Random checks Monitoring requirements Continuous monitoring is not required Frequency of monitoring MCERTS or not Recording of non-compliance Type, frequency and format

Approach to Generators This will differ to the MCP approach in stringency and timescale Generators will be defined and will exclude mobile generators Will apply to sites on which generators aggregate to a thermal input over 1 MW th (that is up for discussion) From 1 January 2019 all generators will require a permit to operate except Back up emergency generators operating less than 50 hours per year Generators on a nuclear site Generators that have come into operation prior to 1 December 2016, Tranche A generators (rating, hours and emissions will determine when and if they need a permit ) Guidance to be consulted on early 2018 Legislation to come in April 2018

Approach to Generators Permits will contain 4 standard requirements ELV for NOx 190mg/Nm3 – not dependent upon AQMA If secondary abatement present ELV must be met within 5 mins of start up Monitoring every 3 years No persistent visible emissions No requirement for particulate matter ELV, but particulate matter to be taken into account for AQ assessment. The operator must provide air dispersion modelling if there is a risk to air quality including: Impact on sensitive receptors Appropriate dispersion Abatement Operating hours Permit to contain additional requirements to ensure no breach of the Ambient AQ Directive.

Pollution Prevention and Control MJAC Permits Library www.mjac.org.uk/permits-library.html Aim to achieve a wide range of sectors and to promote best practise & consistency for members Please submit your permits to Lynda.fawthrop@dudley.gov.uk