The Environment Agency (EA) has shelved plans that would effectively prevent unabated generators performing Triad avoidance.
Under the Medium Combustion Plant Directive (MCPD), generators that take on new balancing services agreements with National Grid, or new Capacity Market contracts, must comply with strict emissions limits by 1 January 2019. They are classified as ‘Tranche B’ generators. Those that do not take on new agreements are classified as ‘Tranche A’ generators and have until 2025 or 2030 to comply.
The EA had originally stated Triad avoidance would be treated the same as providing a balancing service, pushing Triad avoiding generators into ‘Tranche B’ and therefore required to meet new NOx emissions limits by 1 January.
Industry was dismayed that Triad, a billing methodology applied retrospectively by National Grid to determine transmission charges, was being classified by the EA as a balancing service.
The proposal would have effectively ruled out unabated generators from taking part in Triad avoidance next winter, including back-up generators.
While abatement can be fitted to generators, for many businesses the cost could outweigh any savings.
It appears the Environment Agency has listened to concerns. A briefing note published yesterday by the Association for Decentralised Energy states:
“It has now been agreed that, if a Tranche A generator participates in Triads from 2019, this will not change its status to Tranche B, because Triad is not a balancing service.”
Asked by Mission Critical Power‘s sister title, The Energyst, to confirm the information, the Environment Agency said: “Yes this is correct – we will be consulting stakeholders on draft guidance in May.”
Back-up: No rule change
Under the UK interpretation of the MCPD, back-up generators are exempt from controls, provided they run for back-up only. However, the EA has indicated that if they perform Triad avoidance from 2019 onwards they “may not continue to be an exempt generator if [they] carry out Triad operation in 2019 onwards, but will become a Tranche A or B generator”.
That means back-up generators could still provide Triad avoidance, but would come under the scope of the rules as ‘specified generators’. That means they would no longer be classified as ‘back-up’ generators, and as specified generators would need to comply with the relevant permitting and deadlines.
Flexitricity chief strategy officer Alastair Martin welcomed the Agency’s rethink, but argued operators of back-up generation should be able to test them when it makes sense to do so.
“Defra and the Environment Agency are right to keep a very close eye on ground-level NOx. At the same time, emergency power supplies need to be tested on load, or they won’t work. It’s best to test them when the electricity they generate is useful, and the triad system is one way of ensuring that,” he said.
“This change in policy makes more sense than the previous interpretation of the MCPD regulations, though it is still astonishing that diesel farms – which are not emergency power supplies and don’t need to be tested as they don’t need to be there at all – still benefit from a fifteen-year exemption.”
The ADE’s briefing note said that Defra “may address the issue of Triads separately through its proposed Clean Air Strategy consultation” and that the association is seeking further detail from the department and the Environment Agency.