Consultation Summary on Best Available Techniques for Mid-Merit Gas Generators in England
Feedback was gathered on proposed amendments for flexible gas generation, particularly for mid-merit gas generators, from November 2025 to January 2026. The responses highlighted concerns regarding efficiency thresholds and compliance challenges, indicating a need for technology-specific criteria to ensure fairness and environmental protection.
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A 12-week consultation was conducted from November 3, 2025, to January 26, 2026, to gather feedback on proposals for mid-merit gas generators in England using Article 14(6) of the Industrial Emissions Directive. Industry responses revealed disagreement with a proposed energy efficiency threshold of 40%, as it may exclude certain technologies and create uneven compliance pressures.
Some respondents suggested aligning criteria with technology-specific energy efficiency levels. The intent is to allow open cycle gas reciprocating engines and turbines to operate up to 4,000 hours per year, incentivizing lower emissions.
A potential revision of criteria may include thresholds of 35.3% for existing plants and 36% for new plants. The consultation acknowledged ammonia and methane emissions concerns, with recommendations to apply limits only where appropriate. Stakeholder engagement will continue to refine these proposals, balancing environmental protection and operational viability.
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