The grace period for the relatively new sustainability criteria that came into effect on the 5th of October 2015 has now ended. Many companies have expressed a degree of confusion when they are required to submit their independent Ofgem sustainability audit as part of their compliance with the Renewables Heat Incentive Scheme (Amendment) Regulations 2015.
In summary, the report must be submitted within 3 months of the end of the installations annual accreditation date. The audit period is for the preceding twelve months. This may be longer if the due period falls in the grace period. If the Ofgem sustainability audit report is not submitted within the due period, RHI payments will be withheld.
If your installation uses whole crops or residues then we certainly advise the audit is undertaken sooner rather than later. The reason is that the greenhouse gas threshold (GHG) is significantly lower than the Renewables Obligation Order 2015 (ROO). The threshold is 34.8 grams of CO2 equivalent per MJ of heat produced. The B2C2 calculations for whole crops are not the easiest feedstock to calculate. The risk exists that crop feedstocks can be ineligible for RHI payments as they are above the threshold value.
The reason we advocate undertaking the Ofgem sustainability audit sooner rather than later is that it enables the installation to address any audit findings and ensures the audit and report are completed on time without outstanding issues. Neither the auditor nor the installation wish to have any unforeseen problems. Engaging with an audit firm and planning well in advance of the cut-off period for the submission of the Ofgem sustainability audit report prevents unforeseen problems.
EnviroSense conducts attestation engagements performed in accordance with ISAE 3000 (Revised) as required by the RHI and ROO. This is often referred to as the ‘Ofgem sustainability audit’. We conduct the audits for many companies in the biogas, biomethane and biomass sector for both the RHI and the ROO. Please do conduct us if you wish to know more about what is involved in the audit.
Contact: Robin Askey on firstname.lastname@example.org or 07799 032253.