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Do you need a Permit to run your Data Centre Generators?

The MCP Directive, or Directive (EU) 2015/2193 of the European Parliament and of the Council of 25 November 2015 on the limitation of emissions of certain pollutants into the air from medium combustion plants, came into force on 18th December 2015 and was transposed into national law by December 2017. New controls will then apply to all new plant from December 2018. Existing plant have until 2025 or 2030 to comply with Emission Limit Values depending on capacity.

The UK appears to have more stringent rules for “specified generators” and the detailed rules are complex. Existing generators and CHPs (Combined Heat and Power units) may need a permit as early as 1st January 2019.

Power generation has been identified as significantly contributing to the increasing issue. The directives aim is to reduce sulphur dioxides (SO2), nitrogen oxides (NOx) and dust, as agreed under the Gothenburg Protocol.

The MCPD fills the regulatory gap at EU level between large combustion plants (> 50 MW) covered by the Industrial Emissions Directive and smaller appliances (< 1 MW) covered by the Ecodesign Directive.

Key principles of the legislation include:

  • Regulation of MCPs of between 1 and 50MW (equating to electrical output of between 330kW and 17MW),
  • Monitoring of (and potentially regulation of) CO2 levels
  • And an Emissions Limit Value (ELV) based on the size and type of combustion plants.

We must note that the unit of measurement used by the MCPD is the MWth or megawatt thermal power. This is not the same thing as megawatts of electrical power MW, which we are used to seeing as the standard deceptive device for data centre power generators.

1 MWth is a megawatt of thermal power produced by the generating plant (thermal megawatt).

The electric output of a power plant is equal to the thermal overall power multiplied by the efficiency of the plant. So plant efficiency has an impact to the MCP metric of measurement for of plant sizing which is in MWth.

For Data Centres a typical rule of thumb is 1 MW of Data Centre IT load can have a standby generator thermal capacity of around 4 to 6 MWth.

Existing plant may be exempt where the plant doesn’t operate for more than 500 operating hours per year, as a rolling average over a period of five years.

Generators in sites permitted under Chapter II and III of the Industrial Emissions Directive and emergency back-up generators operated for the purpose of testing for no more than 50 hours per year are exempt from these controls.

The above statement might lead data centre managers to wonder if the MCPD will apply to them if their installed generator plant is only intended for one or two hours of weekly testing and the occasional actual real power cut.

The answer is not particularly clear as each EU state has its own slightly different interpretation and application of these rules. So won’t BREXIT relieve UK users from these rules? No – the laws have already been passed by the UK parliament and are in place now*.

The rules appear to apply to any generator of one MWth capacity or more, but if we apply our average efficiency rating as stated above this takes the generator electrical equivalent capacity down to around 250 kVA, which certainly takes in the majority of data centre installation in Europe!

The outcome of these rules is that data centre managers will have to find out if they need to apply for an Environmental Permit.

In the UK the Environment Agency administers and regulates the scheme for England. The other UK regulators include the Scottish Environment Protection Agency (SEPA), Northern Ireland Environment Agency (NIEA) and Natural Resources Wales (NRW).

For UK users the government has published nine complex guidance document to help you through the process;

Capitoline’s advice is to ask your generator supplier for advice on where their equipment fits into the MCPD’s application in your territory. They may of course take the opportunity to try and persuade you it’s time to trade in your old smoky gas-guzzler for the next generation of diesel generators, but on many occasions I suspect they will be right.

You may also be interested in these Whitepapers;

*e.g. The Environmental Permitting (England and Wales) (Amendment) Regulations 2018 SI 110

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