Consultation on proposed best available techniques (BAT) implementation guidance for mid-merit gas generators

Closes 5 Jan 2026

Opened 3 Nov 2025

Results expected 23 Mar 2026

Overview

This consultation sets out our proposals for amendments to techniques for flexible gas generation in England using Article 14(6) of the Industrial Emissions Directive (IED) as the framework where no best available techniques (BAT) conclusions are published.   

We have been limiting operation of open cycle combustion plant to 1,500hrs/year as BAT. We are seeking your views on a proposal for a new category of flexible gas generators called mid-merit which would have longer operating hours and should incentivise the deployment of low oxides of nitrogen (NOx) flexible gas generation. 

Our intention is to encourage operators to reduce their emissions and increase their efficiency by offering them more running hours. This is providing they meet with certain criteria, which could be taken forward as BAT implementation guidance. 

You can find the consultation document with the details of the proposals in the related section at the bottom of this page.

This public consultation is for England only. However, please note that other regulators have been engaged during the preparation of the consultation and we intend to continue working closely with them in developing the proposals further. We will do this in line with the approach agreed through the Integrated Pollution Prevention and Control: The Developing and Setting of Best Available Techniques (BAT) Common Framework, developing UK-wide approaches to industrial emissions where possible.

Why your views matter

This consultation is your opportunity to share insights, raise concerns or highlight unintended consequeces and any other views you may have. 

 Scope of comments 

We will consider comments that are related to the changes specified in this consultation, and related issues as outlined in the questions. For other concerns outside of this consultation, please email the National Customer Contact Centre at enquiries@environment-agency.gov.uk and they will forward these to the appropriate team. 

Responding to this consultation

This consultation will close at 11:59 on Sunday 5 January 2026. We will use your responses to help shape the guidance on mid-merit gas generators. We will consider all responses received by this date before finalising our propsals. You can view the consultation document by clicking on the relevant link in the 'related' section at the end of this page.

Please submit your response using this online consultation tool, as it help us to: 

•    gather all responses in one place
•    summarise responses quickly and accurately
•    reduce the cost of the consultation by avoiding unneccesary printing

If you do not wish to respond using the online tool, you can download the response form using the relevant link in the 'related' section at the end of this page) and email the completed form to combustion@environment-agency.gov.uk with the subject header of “Consultation response: Mid Merit”.  

Please click on the ‘online consultation’ link below to answer the consultation questions.

Ask for a copy of the consultation document

Please contact us if you would like a copy of the consultation document. You can do this by contacting our:  

     

National Customer Contact Centre 

Telephone: 03708 506 506 

Minicom for the hard of hearing: 03702 422 549 

Monday to Friday, 8am to 6pm 

 

Data Protection

How we will use your information 

The Environment Agency will make all responses publicly available after the consultation closes, unless you have specifically requested that we keep your response confidential. This includes comments received online or by email. 

We will not publish names of individuals or personal data. But we will publish the name of the organisation for those responses made on behalf of organisations.  

We will not respond individually to responses. After the consultation closes, we will publish the consultation response document on GOV.UK and contact you to let you know when this is available.   

In accordance with the Freedom of Information Act 2000, we may be required to publish your response to this consultation but will not include any personal information. If you have requested your response to be kept confidential, we may still be required to provide a summary of it. 

Privacy Notice

The Environment Agency would like to keep you informed about the outcomes of the consultation. If you would like to receive an email acknowledging your response and to let you know that the consultation response document has been published, please provide your email address with your response. 

By giving us your email address, you consent for us to email you about the consultation. We will keep your details until we have notified you of the response document publication. 

We will not share your details with any other third party without your clear and full consent, unless required to do so by law. 

You can withdraw your consent to receive these emails at any time by contacting us at combustion@environment-agency.gov.uk

The Environment Agency is the data controller for the personal data you provide. For more information on how we deal with your personal data please see our personal information charter on GOV.UK.   

Please contact the Data Protection team at dataprotection@environment-agency.gov.uk for more information. 

Consultation Principles

We are running this consultation in accordance with the guidance set out in the government's Consultation principles

If you believe the consultation has not been run in accordance with the principles, please email consultation.enquiries@environment-agency.gov.uk.  

Otherwise, for all other queries relating to this consultation, please email combustion@environment-agency.gov.uk  

Please follow the 'Online Consultation' link below to start your response.

Audiences

  • Community groups
  • Medium Combustion Plants
  • Members of the public
  • Non-governmental organisations with an interest in environmental issues
  • Other regulators
  • Trade associations and business

Interests

  • Environmental permitting
  • Installation
  • Permits