FAQs

Not in the first year, but there may be later.

Chapter 5 of the government’s RHI announcement says

Air quality and emissions

As this is a technically complex area we feel it is right to work with stakeholders to establish the most appropriate way of enforcing and administering emissions limits. Therefore, we will be introducing these limits for RHI biomass installations below 20MWth in the next set of RHI regulations in 2012 so that we develop the best possible long term solution and allow industry to get their products appropriately tested.

We expect uptake of biomass under the RHI to be low in the first year of the scheme, and primarily outside urban areas, so the air quality impact of not introducing emissions limits in 2011 will be low.

Similar to those for biogas combustion.

Chapter 5 of the government’s RHI announcement says

Biomethane

The approach taken for biomethane injection will apply the above principles to the biogas used to produce the biomethane, except that the tariff will not be adjusted for any internal process heat returned to the digester or gasifier. The biomethane tariff paid will be reduced to take account of the propane used to upgrade the biogas to the standard necessary for grid injection.

Similar to those for medium biomass plants.

Chapter 5 of the government’s RHI announcement says

Biogas combustion

Our approach for biogas combustion under 200kWth capacity applies similar principles to those used in the enforcement of small-scale biomass combustion and combustion of solid biomass from municipal solid waste:

• The tariff paid will not be adjusted for any ancillary fossil fuel used during combustion, although participants will be subject to a 10 per cent cap on this fuel as a condition of eligibility and also asked to retain information on the amounts used for audit purposes. This approach reflects the principles applied to the enforcement of small-scale biomass combustion.
• Where biogas produced from advanced conversion technologies such as gasification and pyrolysis is combusted, the tariff paid will be adjusted to reward only the biomass proportion of the feedstock used. This approach is similar to that taken on solid biomass contained in municipal solid waste.

For biogas produced from both AD and advanced conversion technologies, the eligible heat output will be reduced for any heat from an external source or which is returned to the process to heat the digester, gasifier or pyrolysis chamber.

None.

Chapter 5 of the government’s RHI announcement says under:

Biomass combustion

Installations up to and including 45kWth will receive 100 per cent of the biomass tariff and will not have to keep fuel receipts. They will have to verify that they are using equipment which is designed specifically for biomass.

No testing is required, but no more than 10% fossil fuel can be used and fuel purchase records must be retained.

Chapter 5 of the government’s RHI announcement says under:

Biomass combustion

Installations between 45kWth and 1 MWth, these installations will receive 100 per cent of the biomass tariff and will not have to submit to a fuel testing regime.

However, use of ancillary fuel or fossil fuel contamination must not exceed 10 per cent by energy content, and we will require that these participants retain information on their fuel purchases for audit purposes and verify that they are using equipment which is designed specifically for biomass.

The same as apply in the Renewable Obligation.

Chapter 5 of the government’s RHI announcement says under:

Biomass combustion

For the large installations of 1 MWth and over, we will mirror the existing procedures applied under the Renewables Obligation (RO) whereby participants receive a tariff adjusted for their fossil fuel use based on fuel measurement and sampling, as verified by Ofgem.

Sampling and measurement will be used for larger systems. There are less onerous schemes for small and medium biomass plants, biogas heat and injection systems.

Chapter 5 of the government’s RHI announcement says

Ancillary fossil fuel use and fossil fuel contamination

Some large-scale renewable heat installations may use feedstock which contain some fossil fuel contamination such as some forms of waste wood. There may also be a need for such installations to use some ancillary fossil fuel for certain legitimate purposes, for example, during the start-up stage.

In order to ensure that the RHI is paid only for genuine renewable heat generation, a fuel measurement and sampling approach will be put in place.

No, but it’s not currently prohibited.

Chapter 5 of the government’s RHI announcement says

Quality timber

We do not expect significant quantities of prime timber to be diverted into energy as a result of the RHI. However, should evidence show that high grade timber is being diverted into heat use, and that turns out to be a perverse outcome from a greenhouse gas lifecycle perspective or causes concerns about deforestation, measures will be introduced to prevent it.

Government sounds a bit ambivalent about it:

Here’s what Chapter 5 of the RHI announcement says

Use of energy crops

As stated in the Waste Framework Directive, Government policy is to specifically deliver an increase in energy from waste through AD. We recognise that, at farm scale, some energy crops may be required in combination with slurries and that such crops can be grown as part of the normal agricultural rotation. Furthermore, there is land available which is not suitable for the production of food crops but which may, therefore, be used to supply energy-crop only AD plants.

It is not our policy, however, to encourage energy crops–based AD, particularly where these are grown to the exclusion of food producing crops. If evidence shows that there is a large scale use of crops in AD and a resulting conversion or change in land used for crops to support AD, then measures will be considered to address this. DECC and Defra will discuss how such a mechanism could work in practice. The Government will, therefore, be investigating possible measures to exclude from RHI support, the large scale use of energy crops in AD.

Because it is considered excessively onerous for smaller installations.

Chapter 5 of the government’s RHI announcement says

1 MWth threshold

There are two key considerations determining the amount of biomass feedstock which will be consumed by RHI generators. Heat generation is typically highly efficient, requiring only around a third of the biomass feedstock used by an equivalent capacity electricity plant. This is balanced by expectations that a number of small/medium sized RHI participants may come forward relatively quickly and collectively consume a significant volume of biomass.

The minimum 1 MWth threshold has been set as a pragmatic compromise in this context. We have decided that setting a minimum 1 MWth threshold will provide us with valuable information on the sourcing trends of medium/large participants and an opportunity to identify issues which need to be addressed when we design the RHI’s sustainability criteria, whilst not placing an onerous data collection burden on smaller non-energy professional participants in the scheme.

They will be exempt.

Chapter 5 of the government’s RHI announcement says

Sustainability reporting

Smaller participants (i.e. below 1 MWth) will be exempt from this reporting requirement (this will include all RHI-eligible biogas combustion installations). On grounds of practicality and in line with the approach developed by the European Commission, where participants use the biomass element of eligible wastes as a feedstock, these feedstock will also be exempt from the reporting requirement.

They will have to provide quarterly reports.

Chapter 5 of the government’s RHI announcement says

Sustainability reporting

From 2011, biomass installations with a capacity of 1 MWth and above and all producers of biomethane will be required to report quarterly on the sustainability of their biomass feedstock for combustion and where it is used to produce biomethane. This requirement will apply to both feedstock sourced in the UK and that imported from abroad.

The government has adopted initially the principle of mandatory reporting in line with the Renewables Obligation and similar schemes.

Chapter 5 of the government’s RHI announcement originally said:

Sustainability reporting

From the start of the scheme, our approach will focus on mandatory sustainability reporting. This will allow time for participants to develop their procurement and reporting systems before specific sustainability criteria are introduced into the RHI and payments become linked to meeting these criteria.

Following this initial sustainability reporting stage, it is anticipated that the RHI will consult on mandatory sustainability criteria, with a view to those criteria taking effect from 2013 onwards [see below]

The approach taken will be consistent with that initially used by the Renewables Obligation (RO), with participants providing information on their biomass feedstock including the country of origin, the source material and details of any applicable environmental quality assurance schemes.

The requirements have since been further defined as shown here.

At present it’s quite complex – the same approaches as are used in the Renewables Obligation would probably have to be applied.

However a potentially simpler way is being trialled:

Chapter 5 of the government’s RHI announcement says under:

Waste

DECC is currently working to develop a fuel measurement and sampling methodology using Carbon-14 dating techniques. If accepted by Ofgem, the Carbon-14 approach may be a cheaper and potentially more representative fuel measurement technique which could reduce the testing burdens on participants.

The total amount of heat produced is adjusted pro-rata for the proportion of the waste fuel that is biomass.

Unless evidence is provided to the contrary, MSW will be deemed to be 50% biomass.

Chapter 5 of the government’s RHI announcement says under:

Waste

Participants who burn MSW will receive the biomass tariff, adjusted pro-rata for the solid biomass content of their waste. Unless participants prove a higher percentage of biomass content, the pro-rata content will be deemed at 50 per cent.

Analysis into the possibility of a dedicated tariff for MSW is underway and we will consider introducing a specific tariff from 2012 providing sufficient evidence is available.

Only municipal solid waste (MSW), including solid recovered fuel (SRF) with less than 10% fossil fuel, and wastes which are at least 90% biomass are eligible (except for anerobic digestion).

Chapter 5 of the government’s RHI announcement says

Waste

Eligible waste feedstock for combustion, gasification and pyrolysis will be limited to solid biomass from municipal solid waste (MSW), including solid recovered fuel (SRF) from MSW.

In addition, other wastes where at least 90 per cent of their energy content is comprised of solid biomass will receive support. Examples of such wastes include waste wood and residues from the paper manufacturing industry.

In 2011, eligible solid recovered fuel (SRF) in the RHI will be limited to SRF from municipal solid waste and SRF waste streams containing no more than 10 per cent fossil fuel. In due course we would like to extend eligibility to SRF from waste streams other than municipal solid waste.

There are no restrictions on the fuel source for AD.

Chapter 5 of the government’s RHI announcement says

Waste

At the introduction of the scheme in 2011 all wastes used to create biogas through anaerobic digestion will be eligible for the RHI.