Solid Biomass Consultancy – RO & RHI

The Sustainability Criteria
If the biomass is to eligible for either ROCs or the RHI, aside from the biogenic content of the fuel having to be equal to or above 90% biogenic content to be classed as biomass, the sustainability criteria of the Renewables Obligation Order (Amended) 2009 and The Renewable Heat Incentive Scheme and Domestic Renewable Heat Incentive Scheme (Amendment) Regulations 2015, must be met and demonstrated by the operators of installations.

With regards to the RHI, payments will be linked to fuels from 5th October 2015 that meet the sustainability criteria. At the time of writing, no formal linkage exists between biomass feedstock meeting the sustainability criteria used in electricity generation and award of ROCs, though formal linkage is expected in the last quarter of 2015.

The sustainability criteria applies to two aspects:
1.Greenhouse gas emissions (GHG): which must meet or be below threshold values in order for the solid fuel to be classed as sustainable if not a waste or biomass wholly derived from waste;

An operator of an electricity generating station, using solid biomass to claim ROCs, must report their GHG emission value in grams of CO2 per MJ of electricity. This means that for most operators the relevant GHG emission threshold is 79.2 gCO2eq/MJ electricity. An operator of a generating station that meets the definition of ‘post-2013 dedicated biomass station’ will be required to report against the GHG emission threshold of 66.7 gCO2eq/MJ electricity.

An operator of a station generating heat and claiming the RHI must report their greenhouse gas emissions (GHG) to meet or be less than 34.8gCO2(eq) per MJ heat generated or MJ of biomethane injected.

2.Land Criteria: which must be met for feedstocks if they are not a waste, or biomass wholly derived from waste;

With respect to wood biomass this criteria is the Timber Standard where an operator must demonstrate indicators S1-S10 are met.

Non-wood biomass (agricultural, aquaculture, fisheries residues and other solid biomass) compliance with the land use criteria must be demonstrated which in general terms can be summarised as not converting forest or woodland, peatland to areas used biomaterial cultivation and harvesting, or was a wetland or diverse grassland, or the production of biomass led to affect nature protection, at any time during or after January 2008.

No-1

Sustainable Solid Woodfuel and the Timber Standard
Solid wood biomass sustainability criteria is included in the Timber Standard with additional information in the Woodfuel Advice Note. There are other supporting documents to manage woodfuel including Ofgem Sustainability Criteria guidance, Consignments and Mass Balance Approach and the Risk Based Regional Assessment – A Checklist Approach (all documents available from the Resource section of this website).

EnviroSense personnel have been working within timber and forestry management supply chains for over 20 years and are well versed with the Timber Standard and the sustainability indicators in the standard (S1-S10), as well as the UK Timber Procurement Policy (UK TPP). Meeting the land criteria and indicators S1-S10 can be demonstrated by ‘Category A’ and ‘Category B’ evidence.

‘Category A’ evidence, at the time of writing is aligned with the UK Timber Procurement Policy and this is only FSC or PEFC certified wood with a valid certified claim from a FSC or PEFC certificate holder. The actual content of certified material must be equal to or greater than 70% in order to meet the requirements of Category A evidence as sustainable (the 70/30 sustainable to legal threshold also applies to mass balance systems for monthly fuels burnt and reported). For different categories to meet Land Criteria Evidence criteria, they can be ‘Category A’, ‘Category B’, or a mixture of both.

‘Category B’ evidence is bespoke evidence that is not FSC or PEFC or a currently recognised forestry scheme by CPET or Ofgem that meets all the land criteria. Bespoke evidence must meet two conditions for use in reporting to Ofgem as sustainable feedstocks:

1.Traceability from the forest to receipt by the operator of the generating station )Timber Standard for Heat & Electricity:
Woodfuel used under the Renewable Heat Incentive and Renewables Obligation. DECC publication.)
2.Forest management in accordance with the indicators S1-S10 (DECC publication. December 2014)

An example of Category B evidence is if wood has been bought from a UK forest holding where the transport documents show origin from the forest or woodland, that has a fully compliant UK Forestry Standard (UKFS) approved forest management plan by either the Forestry Commission (Scotland or England), Forest Service (Northern Ireland) or Natural Resource Wales and the plan has been obtained which is accompanied by a felling licence issued by either of the applicable authorities. This is then fully UKFS compliant. In this instance the Category B evidence would be indisputable. Indisputable is where an operator of a station needs to be in order to have comfort that their fuels will not be deemed unsustainable at a later stage by and auditor.

Apply Caution to Category B Evidence at Present
Category B evidence is not evidence that shows it is probably or likely to be the case the woodfuel is sustainable. Category B evidence is the same level of information required to meet the sustainability criteria – indicators S1-S10 in the absence of FSC or PEFC biomass which have to been assessed by CPET to meet the indicators and UK Timber Procurement Policy. Category B is not a ‘short-cut’ by any means or a softening of the requirements. We suggest your company applies caution in two areas of Category B evidence evaluation:

(a)Traceability and mixing of the wood sources of feedstock that is delivered to the installation as a blend

(b)Application of the Risk Based Regional Assessment in a generic manner to cover all of UK biomass which may not have sufficient evidence to demonstrate that all sources of processing residue are of UK origin and are from sources with approved Forest Management Plans. The reliance of a felling licence alone as stated by the UK Forest Standard is as follows:

“However, the [felling] licence does not extend to the wider context and area covered by a forest management plan – as a result, there will be UKFS Requirements and Guidelines that are not relevant or applicable to the individual licence area.

While the Requirements and Guidelines that are relevant or applicable to the licence area must be complied with, the limited scope of a felling licence necessarily restricts the levels of assurance that can be provided in relation to sustainable forest management.

Accordingly, the minimum levels of UKFS assurance provided by a felling licence will be confined to the discrete operational area and defined as:

i.Legality
ii.Environmental suitability to the site
iii.Conservation of high-value habitats and protected sites
iv.Protection of society values and the provision of opportunities for
public comment
v.Protection of the forest area through a replanting condition”

Why Caution?
In two words: financial implications. Though ROCs are not directly linked to sustainability submissions via the Register, RHI participants feedstock used and Register submissions shall be from 5th October 2015. Ultimately, generating stations do not want RHI payments or ROCs revoked by Ofgem as a result of Ofgem Annual Sustainability Audit results where the auditors’ opinion differs quite significantly from the generating stations interpretation and understanding of sustainability. Part of this is ensuring your company selects the right company to perform the audit (attestation engagement ISAE 3000) and auditor who will work with your company not create unnecessary barriers.

Timber Standard Criteria and Regional Based Risk Assessment
DECC have published a documented entitled, “Regional Based Risk Assessment” which uses a methodology based on FSC Controlled Wood Risk Assessments. The Regional Based Risk Assessment enables operators of generating stations to take a risk-based approach to the Timber Standard for determining legality and sustainability at a regional level opposed to at the forest management unit level. A ‘region’ is defined as an area of sufficiently homogenous conditions where legal and sustainability characteristics or requirements do not significantly differ. One example of a region is a US State such as South Carolina where legislation, forestry and forest management regulation in addition to the ecoregion having a degree of uniformity.

Agricultural, Aquaculture, Fisheries Residues and Other Non-Wood Solid Biomass
If the solid biomass is not wood or derived from wood, in order for the biomass to be eligible for ROCs or RHI payments it cannot be obtained from land that was:

● At any time during or after January 2008 was primary forest.
● At any time during or after January 2008 was land designated for nature protection purposes (unless production of that biomaterial did not interfere with purposes for which this land was designated).
● At any time in January 2008 was peat land (unless the cultivation and harvesting of biomaterial did not involve the drainage of previously un-drained soil).
● At any time in January 2008 was a continuously forested area (unless that land is still a continuously forested area)
● At any time in January 2008 was a lightly forested area (unless that land is still a lightly forested area, or unless the biomass meets the GHG emission criterion when the GHG emissions from land use change are included using actual GHG values)
● At any time in January 2008 was wetland (unless that land is still a wetland).

The above evidence can be indicated and the energy crop deemed sustainable if the energy crop has been assessed to meet the Energy Crop Scheme.

Sustainable Solid Biomass and Recognised Voluntary Schemes
In 2012, Ofgem commissioned a benchmarking study of voluntary schemes that comply or partially comply with the sustainability criteria in order to aid the biomass industry source material of known status in relation to all the land sustainability criteria. At the time or writing (July 2015), Ofgem are finalising the results of a second benchmarking exercise that will include additional schemes such as the Sustainable Biomass Partnership, FSC Controlled Wood forest management standard, Sustainable Forest Industries (SFI) controlled sources (Fibre Sourcing Standard) and possibly Grown in Britain. Currently only Green Gold Label meets all the land criteria. The 2012 results are slightly misleading as for FSC and PEFC biomass relate mainly to wood from forests that have achieved forest management certification and must constitute a ‘forest matrix’. Therefore wetlands are not habitats likely to receive FSC or PEFC certification. A summary of the Ofgem benchmarking exercise is below:

(diagram coming soon…)

Mass Balance Systems
The biomass used in the furnace per month and reported to Ofgem on the Register and data submissions must be at a minimum 70% sustainable to 30% legal in weight (with reference to term sustainable that means legal and sustainable as the biomass must be legal to in order to be sustainable. This can be managed by a mass balance system and disaggregation of blends into consignments which are unfortunately a burden unless Ofgem agree a blend as a consignment. EnviroSense can work with your company to develop and manage a mass balance system for solid biomass received, solid biomass used for heat or electricity generation and reported to Ofgem. Please see our webpage page:

< Mass Balance Systems Support Sustainability Internal Audit Programme
As the Ofgem Sustainability Audit is performed once a year it is best advised, certainly with respect to wood biomass and residues that are non-wood, to be well-versed with your suppliers and biomass origins via periodic conduct of internal audits. Other companies are invariably auditing your biomass supplier and overzealous and too frequent auditing will not engender good supplier-customer relations.

We suggest your company pays particular attention to claims on sustainability proportions of blends received and the origin of biomass sources (processing residue, forestry residue, arboricultural arisings) and conducting internal audits provide assurances and demonstrates robust internal audit evidence to the auditor conducting the Ofgem Sustainability Audit. Internal audits should preclude the auditor having to visit your supplier in many instances if carried out appropriately.

Additionally, conducting a pre-audit of the sustainability criteria requirements prior to your companies commissioned sustainability audit for Ofgem, can pre-empt or identify any potential issues and fundamental errors that could be resolved prior to the sustainability audit. In doing this, negative findings will not be included in the sustainability audit report that will be reviewed by Ofgem.

Annual Ofgem Sustainability Audit Support
EnviroSense can participate and represent your company, with your companies support, during the annual sustainability audit. This service has been provided for a number of different audits and sustainability audits foist upon our clients. Unfortunately this can only be carried out following either an internal audit or a degree of consultancy support in order for EnviroSense to be versed with the installation and your sustainability programme.

Why EnviroSense?
Solid biomass consultancy is a niche that requires a mix of biomass industry experience and familiarity of heat and electricity generating installation operation how Ofgem operate and the accreditation process, design and use of mass balance systems, application of Ofgem guidance, RHI and RO sustainability criteria and in particular Category A and Category B evidence, Timber Standard and the benefits and limitations of Regional Based Risk Assessment. This is a curious mix and years of experience by EnviroSense personnel in the timber industry involving legal and sustainability assessments and auditing, then over recent years providing consultancy services for operators of generating stations, traders, biomass producers and forest owners. All experience gained by EnviroSense personnel has fortunately enabled us to be in a good position to provide trusted advice.

Please do contact us with any questions you may have or should you wish to discuss a potential project:

e: robin@envirosenseltd.co.uk
e: info@envirosenseltd.co.uk
t: 01531 637396