The Department of Energy and Climate Change (DECC) held a workshop on the 10th of February to consider the future of the Biomass Suppliers List.
The option of retracting the BSL does not seem a viable option. The BSL, functional or not, seems to be ingrained into the process for indicating compliance with the RHI sustainability criteria wood fuel for biomass.
The workshop which EnviroSense attended showed that DECC is open to ideas and more than willing to engage with a variety of stakeholders. Two points that EnviroSense has been keen press are:
1. What constitutes Category A evidence.
A failure of the BSL is that if a receiver of FSC or PEFC material sold by a supplier with valid FSC or PEFC certificate, for example a farmer receiving roundwood or chip to burn from UPM Tihill in their accredited installation, according to the BSL the farmer must hold FSC or PEFC chain of custody in order for this to be classified as “Category A”. This is incorrect as the farmer is essentially the end of the chain, not breaking the chain and receiving Category A sustainable wood. This point has been clearly shown by CPET guidance (Central Point of Expertise on Timber).
The consequence is that BSL require a Regional Based Risk Assessment (RBRA) preformed on that FSC or PEFC wood. submitted by the farmer. The fact is exacerbated by the fact that example of the “the farmer” is in fact any non-domestic applicant to BSL which receives FSC or PEFC fuel and does not have FSC or PEFC certification. This indicates the lack of understanding of Category A evidence and how the industry operates.
2. Payment for an audit in order to speed up the approval process.
Opposed to a length administration process, the application and RBRA (if applicable) could be approved at an audit and authorisation given at the end of the audit.
As users of the BSL know, application can take months. Participants at the workshop stated there is a lack of industry and product specific knowledge within the BSL. Unfortunately is was not pointed out that there appears to be a few key persons within BSL keeping it together and being as responsive as they can under the circumstances.