Guidance

Emissions to air from Large Combustion Plant during black start events: RPS C11

Published 21 April 2020

This guidance was withdrawn on

This COVID-19 regulatory position statement has expired.

Applies to England

© Crown copyright 2020

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This publication is available at https://www.gov.uk/government/publications/emissions-to-air-from-large-combustion-plant-during-black-start-events-rps-c11/emissions-to-air-from-large-combustion-plant-during-black-start-events-rps-c11

This COVID-19 regulatory position statement (RPS) only applies to the emission limit values (ELVs) stated in your permit for emissions to air from your Large Combustion Plant (LCP).

You must notify your Environment Agency regulatory officer by email before using this COVID-19 RPS.

1. When this COVID-19 RPS applies

This COVID-19 RPS only applies when, during black start events, your LCP cannot comply with the ELVs for emissions to air. Black start means when you restore electricity supply after a significant electrical emergency, as instructed by the National Grid.

You must be able to demonstrate that you have taken all reasonable steps to comply with the ELVs in your permit. You must have a procedure in place for minimising emissions during a black start event.

2. Conditions you must comply with

You can exceed the ELVs for LCPs for oxides of nitrogen, sulphur dioxide, dust and carbon monoxide as stated in Table S3.1 of your permit providing you:

  • are operating under National Grid instruction during a black start event
  • send a written report to the Environment Agency as soon as you can after operating under this COVID-19 RPS

In your report you must include details of the:

  • duration of the event
  • emissions to air and the potential impact – you must refer to the Joint Environmental Programme’s report Air quality impacts associated with black start operation, ENV/656/2020

You must comply with all the other requirements of your environmental permit.

3. Enforcement

A COVID-19 RPS means that the Environment Agency will not normally take enforcement action against you provided:

  • your activity meets the description set out in this COVID-19 RPS
  • you comply with the conditions set out in this COVID-19 RPS
  • your activity does not, and is not likely to, cause environmental pollution or harm human health
  • you have taken all reasonable steps to comply with your permit

If you operate under this COVID-19 RPS, but think you may no longer be able to comply with its conditions, you must tell the Environment Agency immediately.

The Environment Agency will monitor how operators use and comply with this COVID-19 RPS through its proportionate, risk-based inspection and monitoring activity.

4. When to check back

This COVID-19 RPS will be withdrawn on 31 July 2020 unless we extend it. After this date you must comply with your permit.

5. Contact the Environment Agency

You must notify your Environment Agency regulatory officer by email before using this COVID-19 RPS.

Put this wording in the title of your email:

  • COVID-19 RPS C11 – for information

If you need us to respond to a query please also add ‘for action’ at the end of the title of the email.

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