Relatively short notice from Ofgem perhaps. Though this was anticipated before the end of the year. However, Ofgem have allowed suitable time to enable power stations to amend their Fuel Management and Sampling procedures, gain approval and manage feedstocks sustainability accurately in addition to account ing for GHG intensities.
The finer details of what evidence is required for Category B evidence of sustainability, how sustainability can be evidenced, compounded by the problem of many small woodland owners not having forest management plans and certification, may leave some installations exposed. Too many assumptions could be made within the Risk-Based Regional Assessment, of which an auditor conducting the ‘Ofgem Sustainability Audit’, may take exception to (see EnviroSense webpage and paragraph regarding applying caution to Category B evidence). This scenario presents a risk.
Conversely Category A evidence, which an auditor conducting the annual ‘Ofgem Sustainability Audit criteria’, can easily understand, will not cover all fuels for all installations. This will mean the installation having to manage their mass-balance system carefully to ensure fuels are categorised correctly. Caution is required and installations should not sail too close to the ’70/30′ sustainable / legal threshold (see Woodfuel Advice Note). Next Spring 2016, when installations are audited under the RO obligation, could indicate incorrect categorisation of fuel which may tip one month below this 70/30 rule. In fairness, it is unlikely that an auditor will spot cases of incorrect categorisations of fuels as many auditors conducting the audits are basically auditors without wood industry or forestry experience. The number of feedstocks received by installations can mean managing a lot of feedstock data and this presents a notable amount of information for an auditor to verify. The negative consequence of formal linking in a market where eligibility of wood fuel is unfortunately subject to debate in some situations, ultimately may lead to revoking of ROCs payments by Ofgem. Hopefully this theoretical situation will not arise.