Here at Woodfuel Pathfinder Towers we have been trying to
decipher the recent slew of information on the Renewable Heat Incentive and
related matters.
Just as we got our
collective heads around the review of the Clean Air Act, new Ofgem guidance on
heat metering and scheme administration and announcement of DECC’s budget management mechanism yet another consultation on the RHI has been issued.
Needless to say the document is long and technical so we
have attempted to extract the salient points from the executive summary.
The proposals are important and
anyone considering investing should set aside a some to read the document and
familiarise themselves with the proposed changes, particularly as we may have
missed something.
Before we get going we thought we would highlight the
following tables that show the latest position on RHI uptake and payments (England only, see Ofgem web site for full report).
Renewable Heat Incentive: Providing certainty, improving
performance
Executive summary – key points:
- Controlling spend while providing certainty and
transparency is a far greater challenge than simply keeping within a
pre-determined budget.
- The consultation sets out proposals for longer-term
budget management and how DECC will aim to provide market certainty alongside
budgetary control.
- These proposals would only apply to new
applications and only to the RHI scheme as it currently stands (i.e.
non-domestic). Proposals would be extended to other technologies brought into
the non-domestic scheme, which will be consulted on from September 2012.
- Budget management proposal is to use a flexible degression-based system. Under
this system tariff reductions for new applications would occur if deployment
was approaching pre-determined triggers, at which point a small tariff
reduction would occur automatically.
- Proposed
triggers for each technology and for the RHI overall will be based on the
level of deployment required to keep us on a trajectory to deliver the 2020
renewables target.
- Degression
announcements would be made quarterly, with one month’s notice being given
for any reductions.
- Triggers
for tariff reductions will be set out in advance and progress towards those
triggers will be monitored and made available monthly on the DECC website.

- The size
of possible reductions would also be set out in advance, with a small
reduction if deployment is slightly above that needed, and a larger reduction
if deployment is significantly higher than that needed for the 2020 renewables
targets.
- In addition, DECC is proposing to carry out
periodic reviews of the RHI, starting in
2014, to take stock of the evidence on the operation of the scheme and
consider ways of improving it further. These reviews will provide an
opportunity to recalibrate tariffs and if necessary, make changes to the tariff
structure.
- DECC has set out a potential option, enhanced preliminary accreditation.
This would allow applicants to develop and accredit an installation that, when
built, would receive a tariff guaranteed at the point of application for
enhanced preliminary accreditation. Applications would be subject to time and
size limits according to each technology.
- It is equally important that the RHI is
sustainable in the wider sense, so DECC will put forward proposals for biomass sustainability criteria.
- The
proposals are that biomass used for heat will have to achieve a lifecycle
greenhouse gas (GHG) saving of 60% against an EU fossil heat average. The
lifecycle assessment would take account of emissions from cultivation,
processing and transport of the biomass, and reflect the conversion efficiency
of the boiler plant. This would ensure a significant GHG saving relative to the
use of coal, oil or fossil gas for heating.
- Furthermore, for wood-fuel, we propose that the land criteria correspond to meeting
the UK public procurement policy on wood and wood products. This approach
requires that suppliers should have available documentary evidence
demonstrating the wood supplied is from legal and sustainable sources or is
from a licensed Forest Law Enforcement, Governance and Trade (FLEGT) partner.
- For installations below 1MWth capacity, DECC proposes
that, from April 2014, they have to purchase their biomass from an approved supplier list. For larger
installations DECC proposes that RHI participants would provide reports on the
sustainability of their fuel to Ofgem.
- In the March 2011 RHI policy document DECC committed
to introducing limits on the emissions of particulate matter (PM) and oxides of
nitrogen (NOx) from biomass installations up to 20MWth capacity. This consultation proposes what the compliance
regime should be for those emissions limits.
- The consultation sets out proposals for simplifying the metering arrangements. DECC
proposes that, in most cases, heat transported in external pipes insulated to a
specified standard will be eligible heat use and will not be deducted from RHI
payments. Therefore, where all heat uses are eligible, only the metering of
eligible renewable heat generation would be required.
Other improvements:
- clarifying the eligibility around ground source
heat pumps
- allowing renewable heat plants to be moved under
the RHI
- clarifying eligible heat use
- simplifying the rules for biogas metering
- ensuring biomass boilers are not oversized
specifically to claim the tier 1 tariff
- dealing with how the Retail Price Index (RPI)
applies to low tariffs, such as large biomass
With regard
to boiler sizing Biomass DECC has anecdotal evidence that there may be
installations of biomass boilers which are inappropriate for the heat demand
they are intended to serve but have been sized in order to claim the tier 1
tariff only. DECC considers this to be poor practice and is likely to have a
detrimental long-term financial impact on the owner of the installation. DECC
intends to introduce an eligibility requirement to prevent such installations
from benefitting from the RHI.
For all the
proposed changes, apart from those on sustainability, within this consultation
grandfathering will apply; only applications which are accredited after these
changes come into force will be affected. All those installations accredited
currently or before these changes, will have to meet current eligibility
requirements.