As many generating stations are aware, the government introduced mandatory sustainability requirements and associated third-party verification for participants using solid biomass, biogas or producing biomethane which are claiming the RHI on the 5th of October 2015 onwards. Participants claiming the RHI are required to submit an annual sustainability audit report demonstrating compliance with the sustainability criteria. The report must be independently verified and submitted by the operator of the generating station to Ofgem. It is the operators’ responsibility to ensure the report is correct and submitted on time and not the verifiers. The engagement performed by the verifier must indicate each organisations responsibilities, the operators’ being the submission of the report.
The question that is not wholly clear to many is when the report is required. In brief, this is three months after the tariff start date each year. With regards to biomethane procedures, it is the annual date when the participant first registered as a producer of biomethane. The report applies to the preceding twelve months and the submissions made.
As with new legislation, a grace period has been applied from the 5th October to the 5th April. Any participants claiming the RHI with greater than 1 MWth with their tariff start date do not have to be audited in that period. Thereafter they do within three months of their specific tariff date.
The purpose of the audit, which can be found in greater detail on our website here , is in basic terms to ensure tax payer’s money is not used by claimants using fuels that do not meet the sustainability criteria, this is both the land criteria and GHG threshold except in the case of wastes which are exempt but still require verifying within the Ofgem sustainability audit.