The directive aims to control emission from combustion plants in the 1-50 MW thermal input range.
The NFU is interested in this consultation as it believes that the following agricultural sectors may be affected:
- Pig and poultry units using boilers for heating livestock buildings;
- Cereal growers using boilers for grain drying
- Horticultural members using boilers for glasshouse heating
- Larger dairy units may fall into this directive for water heating.
Key points of our response include:
- Concerns over how vague the current implementation plan is
- The NFU does not believe that generators with an aggregated rated thermal input <1MW (at a single site) should be required to comply with low emission limits
- The NFU believes that all agricultural combustion plants and generators should be exempt from this Directive regardless of size or hours used due to the requirements being disproportionate to their impact for an SME
- The NFU does not agree that holdings hosting an MCP of 1 MW or above forces the holding to employ a greater number of staff.
Please note that MCPs which operate less than 500 hours per year will be exempt. The consultation also covers generators however it excludes ‘back-up generators which are operated for testing for no more than 50 hours per year’.