Less than two years separate us from the entry into force of new EU regulations for medium combustion plants. The MCP Directive tightens emission standards, which apply not only to thermal and industrial power plants but also to many public utilities. The challenge remains the Polish heating system, which is one of the largest in Europe and the most emission-intensive. It can hardly claim to be ready for change, and time is pressing.
About 143,000 medium combustion plants are in the EU. They are used to generate electricity, heat, and cool public and residential buildings, as well as provide heat and steam for industrial processes. Current climate policy seeks to increase energy efficiency and reduce emissions in all sectors. District heating and industry are quite a challenge in this regard. Especially in Poland, where the biggest problem remains cost and the lack of a long-term strategy for modernizing heating systems. After all, it’s not just about meeting the 2025 limits but thinking about the transformation from a broader perspective.
With less than two years until the regulations come into force, this is only the beginning of the road ahead for Polish companies. There will come a moment when temporary preventive measures will no longer suffice, and we will face the goals of increasing the share of RES (the 2023 raised target is already 42.5% of renewable sources) and creating efficient heating and cooling energy systems. Then we will be left with the question – what next?
That’s why today we’re taking a detailed look at the MCP directive, which will define not only the limits but also the model for registering facilities and the frequency of emissions monitoring.
What is the MCP directive?
We colloquially refer to the Directive of the European Parliament and the Council (EU) 2015/2193. It concerns the limitation of emissions of certain pollutants into the air from medium combustion plants, i.e. plants with a rated thermal power between 1 MW and 50 MW regardless of the type of fuel used.
The directive was introduced into Polish legislation in 2018. It includes provisions to reduce emissions of sulfur dioxide (SO₂), nitrogen oxides (NOx), and dust into the air from medium-sized facilities, to reduce the negative impact of their activities on the environment and the health of citizens. The directive also sets rules for monitoring carbon monoxide (CO) emissions.
What will be the emission limits?
Emission limits depend on factors such as the type of medium facility, the type and share of fuel used, and thermal power (MW). Deadlines are also crucial.
- Installations with a capacity greater than 5 MW are required to comply with the new standards by January 1, 2025.
- Installations with a capacity not exceeding 5 MW by January 1, 2030.
MCP: Allowable emissions at existing facilities
It does not pay to underestimate the new regulations, as failure to meet the requirements will result in not inconsiderable financial penalties. In the long term, this could threaten the solvency of companies. The following tables contain emission limits for existing medium combustion plants.
Table 1 Emission limits (mg/Nm3) for existing medium-sized combustion plants with a rated thermal power of not less than 1 MW and not more than 5 MW, other than gas engines and turbines
Table 2 Emission limits (mg/Nm3) for existing medium-sized combustion plants with a rated thermal input greater than 5 MW, other than gas engines and turbines
Table 3 Emission limits (mg/Nm3) for existing engines and gas turbines
MCP: Emission volumes for new plants
The directive also indicates emission limit values for new medium combustion plants, i.e. those established after December 19, 2018.:
Table 1 Emission limits (mg/Nm3) for new medium combustion plants, other than gas engines and turbines
Table 2 Emission limits (mg/Nm3) for new engines and gas turbines
Limits, registration, and monitoring
The directive also includes rules related to the registration of new and existing facilities, as well as provisions for the frequency of operator emission controls and monitoring:
- for medium facilities with a rated thermal power of not less than 1 MW and not more than 20 MW – once every three years,
- for medium facilities with a nominal capacity exceeding 20 MW – once a year.
The measurements apply to pollutants for which the directive establishes an emission limit for the facility, as well as to CO emissions at all facilities. Significantly, the first measurements will be carried out as early as the first four months after the permit is obtained, the facility is registered, or the date operation begins, whichever is later.
The state of Poland’s district heating systems is mainly a challenge
The demand for thermal energy in Poland in 2020 exceeded 79 TWh. More than 75% of this heat was generated from the combustion of solid fuels, mainly hard coal.
Due to the high consumption of conventional fuels in heat generation, the domestic heating sector emits about 68 million tons of CO2 annually. The main sources of pollution are district heating and combined heat and power plants, characterized by outdated and inefficient systems. They are the ones that will be most severely affected by changes in the law at the beginning of January 2025.
As representatives of the NIK pointed out, the public administration’s actions to date have also failed to reduce pollution and develop efficient district heating systems. These, are defined as systems that use at least 50% RES, 50% waste heat, 75% cogeneration heat, or 50% use a combination of the energy as mentioned above and heat to produce heat or cold. Moreover, there has been no monitoring, no planning, and no preparation of a strategy for modernizing the heating industry, acting primarily in an ad hoc manner. As a result, Poland faces a low percentage of district heating systems that meet the criteria of new EU regulations, including those related to energy efficiency.
Where are the opportunities?
Meeting the limits of the MCP directive, increasing the share of RES, and improving energy efficiency must be achieved by replacing outdated and inefficient installations and heating equipment. The concern is invariably the cost of such investments. In recent years, EU regulations have put renewable hydrogen generated from RES electricity at the center. Its total consumption in sectors of the European economy is expected to exceed 20 million tons in 2030, and financial instruments, including the European Hydrogen Bank, are planned for this purpose. Their goal is to make the price of hydrogen more attractive and competitive against traditional fuels. The use of hydrogen in heating will be no different.
Hydrogen-oxygen boiler – the way to modernize the heating sector
We are developing the hydrogen-oxygen boiler which is the answer to the growing problem of transforming medium-sized facilities. It is an efficient and environmentally friendly device whose operation is based on the combustion of substrates in the form of pure hydrogen and pure oxygen (not air), thanks to which we achieve the elimination of CO2 emissions, as well as SOx, NOx, dust, and flue gases, ensuring zero-emission heat production.
In the case of supplying fuel and oxidizer directly from an electrolyzer connected to the RES farm, this solution will allow the use of closed-loop renewable energy, without stack losses, to feed the district heating network. It will also make it possible to reduce the time, size, and cost of the investment, thanks to the possibility of using existing infrastructure and transmission networks. This is because the solution does not interfere with the heat distribution system or internal installations at heat consumers, as it distributes heat in the same way as existing systems. The energy source and fuel are replaced.
Hydrogen fuel solutions already represent a major opportunity for decarbonizing medium-sized facilities, contributing to environmental goals, and eliminating the rising costs of emission allowances, penalties, and fuels themselves.
