A recent flurry of calls indicates that many companies may commissioning the ISAE 3000 attestation engagement quite close to the cut-off date when the report must be submitted. This date is the 30th June for solid wood or anaerobic digestion. The consequences according to the Ofgem guidance is potentially withholding the ROCs until the report has been sent to Ofgem. Ofgem make it clear that the onus is on the operator and not the company performing the attestation engagement.
For many anaerobic digestion plants, compliance with the sustainability criteria will be relatively easy based on the fact of using feedstocks than may be categorised as wastes. However, despite the sustainability criteria being exempt in such cases, the attestation engagement still needs to be performed. In these instances, the practitioner performing the engagement will consider if monthly submissions to Ofgem are accurate, the feedstocks are in fact wastes, basic chain of custody over the waste from supplier to operator and not mixed waste feedstocks, robust data for the receipt over the weighbridge of feedstocks, mass-balance (if in operation), stock management and exit of wastes such as packaging over the weighbridge and other such points to support the conclusion that reporting has been correct and accurate.