2020 feels like a lifetime ago. When you consider what a difference five years makes, you’d be forgiven for thinking 2030 is another lifetime away. However, in the context of CapEx project planning, 2030 will be here before we know it. It will also bring with it one of the biggest legislative updates off-grid plant managers have had to face in recent years: the final compliance deadline for the Medium Combustion Plant Directive (MCPD).
First introduced into UK law in 2018, the MCPD aims to restrict the volume of specific emissions that any piece of equipment that burns fuel – such as boilers, furnaces and generators – can release. This is managed through the application of emission limit values (ELVs). In particular, the MCPD aims to curb the emission of carbon dioxide (CO2), nitrogen oxides (NOX), sulphur dioxide (SO2) and particulate matter (PM).
While there are noted exceptions – such as emergency power applications and MCPs with fewer than 500 operating hours per year – any new MCP installation since 2018 has had to comply with the relevant ELVs set out in the directive. Installations operational prior to 2018 were then given specific compliance deadlines based on their capacity. Those with a capacity of between 5–50MWth needed to comply by 1 January 2025, and those sized 1–5MWth will need to do so by 1 January 2030. This will be the final compliance window and should ensure all MCPs are covered by the directive.
So, what does this mean in practice for off-grid plant managers?
Put simply, the January 2030 deadline is likely to affect any organisation running a steam boiler or boiler plant room on high-carbon fossil fuels, such as oil, which emit high levels of pollutants during the combustion process. Crucially, the 2030 compliance deadline also covers total system capacity and includes the operation of multiple generators with a capacity below 1MWth if their combined output exceeds that value.
While the compliance thresholds are changing, so too are the penalties. In December 2023, the Environment Agency, which is the enforcing body in England[1], upgraded its sanctions for failing to comply with the MCPD from a maximum fine of £250,000 to potentially unlimited fines[2]. While the penalty will understandably vary depending on the level of intent, size of the plant and severity of the offence, the overarching message is a strong one: compliance will not be optional, especially with a full five years between the 2025 and 2030 deadlines.
However, while the penalties are undoubtedly severe, there are plenty of routes forward that do not involve completely replacing your boiler.
One option I often see targeted at oil users is switching to a low-NOX burner. Burner retrofits and pipework are certainly one of the most pragmatic ways of tackling the issue, but I would urge caution over those which only promise to tackle NOX. After all, the MCPD aims to reduce a wide range of harmful emissions, which includes but is not limited to NOX. For example, a low- NOX burner is unlikely to deliver a significant reduction in PM2.5 emissions when burning oil, which is a key ELV set out by the MCPD.
Ultimately, the most effective way to work towards MCPD compliance is to tackle emissions at source and look at the fuel itself.
As an aside, switching to HVO is unlikely to support MCPD compliance. While it is typically viewed as a more sustainable alternative to oil, most of the carbon savings are generated through the supply chain rather than the combustion process itself.
This leaves us with LPG. LPG is a smoke-free burning fuel that emits far fewer pollutants than oil as, during combustion, LPG produces much lower levels of NOX and SO2 than oil, while virtually eliminating PM. This holds the key to MCPD compliance.
When it comes to oil-to-gas conversions, in many cases the only CapEx requirement for the plant room is a burner retrofit and pipework. As already mentioned, this is much more cost-effective than replacing the boiler. Indeed, I recently worked on a project for a large hotel and spa resort where the cost to retrofit three burners was just a third of what it would have cost to replace the whole boiler.
Switching from oil to gas also offers a number of other benefits, including lower fuel costs, reduced servicing and maintenance requirements, and significant reductions in carbon emissions. To put this into context, we worked with the team at Carden Park Hotel – which boasts almost 200 rooms, a spa and two restaurants – to transition from oil to gas. This resulted in a 21% reduction in energy costs and a 23% reduction in carbon emissions.
Ultimately, time is still on everyone’s side. Organisations with a capacity of 1–5MWth can only apply for a compliance permit from January 2029, so there is plenty of scope to factor MCPD compliance into any short-to-medium-term CapEx project planning.
However, given the severity of non-compliance, I would urge those responsible to avoid putting MCPD compliance on the back burner – no pun intended – for too long. Changing your fuel source may sound like a daunting task, but in the long run, it will likely have far-reaching commercial, operational and sustainability benefits beyond MCPD compliance for many years to come.
For more information on switching from oil to gas, please visit: https://www.flogas.co.uk/business/oil-to-gas.
[1] *The MCPD is also enforced by the following bodies: in Wales by Natural Resources Wales; in Scotland by SEPA; and in Northern Ireland by District Councils.
[2] https://2ea.co.uk/wp-content/uploads/2024/02/2EA-MCPD-Enforcement.pdf
