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WHITE PAPER
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By Alex Rabbetts , European Data Centre Association
www . eudca . org
Implications for data centres as a result of the new EU medium combustion plant directive
What ' s driving the directive ? Air pollution levels are still problematic in many parts of Europe , and citizens of the union continue to be exposed to air-polluting substances , potentially compromising their health and well-being . Power generation has been identified as significantly contributing to the increasing issue . The aim of the directive is to reduce sulphur dioxides ( SO2 ), nitrogen oxides ( NOx ) and dust , as agreed under the Gothenburg Protocol .
What is the directive and its implications ? The Directive regulates the fuel emissions in plant machinery with a rated thermal input equal to or greater than 1 MW and less than 50 MW . The Directive also covers the issue of possible future regulation for monitoring emissions of carbon monoxide ( CO ). The Emission Limit Values ( ELV ) apply from 20 December 2018 for ‘ new plant ’, and from 1 January 2025 for bigger existing plants ( 5 – 50 MWth ) and from 1 January 2030 for smaller existing plants ( 1 – 5 MWth ). ‘ Existing plant ’ means a combustion plant put into operation before 20 December 2018 or for which a permit was granted before 19 December 2017 , provided the plant is put into operation no later than 20 December 2018 . The MCP from a data centre power perspective means for example generator sets standby and primary use .
Will it affect my business ? The short answer to this is ' yes ’. The Medium Combustion Pollutants Directive will have a direct impact on data centre design and operation , primarily in relation to standby or primary generator sets . Due to the typical capacities utilised in the industry , many data centre generators will be required to meet the Directive ’ s local implementation requirements . As a minimum , the Directive will require plant emissions to be monitored on a regular basis by the data centre operator . Where existing equipment is not meeting emission limits , the equipment will need to be abated / modified .
Will there be any exemptions ? Existing plants 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 . Firing solid fuels emission limit value for particulate of 200 mg / Nm3 .
When will the Directive come into force ? The Medium Combustion Plant ( MCP ) Directive came into force on 18 December 2015 and will need to be transposed into domestic law by each member state by 19 December 2017 .
What about future developments ? The European Commission will review the need to revise Emission Limit Values for new plants to regulate CO emissions , by 1 January 2023 . Following that , the MCP Directive will be reviewed every ten years with a focus on new plant provisions .
Improving air quality The Medium Combustion Plant Directive intends to improve air quality , and reduce the pollution impacting health , by controlling air emissions to much of the generating plant located in urban areas . MCP Directive defines Emission Limit Values [ ELV ] for key pollutants , and periodic monitoring requirements . The method for assessing compliance are not clearly defined .
This will challenge those aggregating MCPs with different types of combustion units , that are exhausting through a common stack and also for units fitted with pollution abatement equipment since the operator is required to demonstrate that the abatement is continually effective .
Monitoring still requires national guidance on which equipment , methods and quality assurance systems will be needed in order to demonstrate compliance . For dust measurement , the CEN standard defines sampling equipment for Large Combustion Plant that ’ s not suitable for Medium Combustion Plant
Key dates : The MCP Directive comes into force : 18 December 2015 and transposed 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 . n
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