1. MJAC
Founded 1928
December 2016

2. Technical Committee (Air Reg)
Committee Members:
Lynda Fawthrop
Ian Rathbone
Gerg Jambor
Vacancies - Any interest

3. 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

4. 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

5. 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.

6. 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

7. 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

8. 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

9. 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

10. 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

11. 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

12. 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.

13. Pollution Prevention and Control
MJAC Permits Library
Aim to achieve a wide range of sectors and to promote best practise & consistency for members
Please submit your permits to