We have slowly been developing guidance for data centre operators regarding the Medium Combustion Plant Directive and Specified Generator Controls. MCPD is not in itself unduly complex or problematic – the fun starts with the SGC, which are unilateral domestic measures to try and “regulate out” diesel generator farms set up under Contracts for Difference where individual plant sits just below MCPD and other thresholds but nevertheless collectively they threaten air quality. As ever, data centre operators and others are caught in the crossfire and the collateral damage is that anyone who engages in Demand Side Response (DSR) or triad avoidance will find it a lot more difficult in future. There are three main rules of thumb:
- MCPD permits will be needed for new plant operational on or after 20 December.
- Existing plant will need permits eventually, by 2025 or 2030 depending on size.
- If you do any form of demand side response or triad avoidance you will almost certainly need to fit abatement, sooner or later, or cease activity.
The Environment Agency guidance should be your first port of call: this Decision Tree and briefing note represent our interpretation of that guidance and do not constitute legal or professional advice. If you have any queries about the guidance or wish to suggest amendments or corrections then please get in touch. The EA guidance is currently still in consultation stage so there may be further amendments.