- The MCS 040 Biomass Maintenance Standard
- 10-year Meter Recalibration Requirements
- Fuel Quality Requirements for BSL
- Suspension of Fuel Quality Requirements for Wood Pellet Fuel Only
Do you have concerns over changes to environmental legislation or permitting?
Over the past year, the regulatory requirements for the operation of biomass boilers have tightened up significantly to ensure that the emissions are not causing any detriment to air quality.
If you are a participant of the Non-Domestic Renewable Heat Incentive (NDRHI), you will be aware that failure to comply with ongoing obligations could result in payments being suspended or permanently withheld. The following updates to the NDRHI therefore need to be adhered to where appropriate to ensure that your investment is protected.
The MCS 040 Biomass Maintenance Standard
In June 2022, the government introduced a requirement for owners of biomass systems accredited to the RHI to ensure they have been properly serviced. This involves annual preventative maintenance checks. HETAS has launched a registration scheme for competent servicing businesses. To become approved, the businesses will need to show competence to maintain the boiler categories and groups identified. Those involved with the servicing of RHI boilers will need to register with HETAS and provide evidence of experience and training.
RHI participants will need to make sure that their future services are carried out by an approved business on the scheme, or this will be treated as a non-compliance issue. From 1 April 2023, as part of the annual declaration submission, participants must confirm that they have completed the maintenance check and met the maintenance standard.
10-year Meter Recalibration Requirements
In October 2022, Ofgem sent out a communication that requires every RHI participant to recalibrate all payment meters and steam measuring equipment at least every 10 years (or in line with manufacturer’s instructions where available, whichever is sooner). The 10-year start date begins from when the meters were first installed, most recently recalibrated or replaced.
To comply with this requirement, RHI participants can choose to either recalibrate or replace their meter.
Fuel Quality Requirements for BSL
In February 2022, the Government introduced amended regulation requiring that those registered on the Biomass Suppliers List (BSL) must also meet the relevant quality standards in schedule 4A.
To comply:
- All wood pellets must meet the ENplus A1 standard or an equivalent standard (**temporarily suspended)
- All other woodfuel must meet fuel quality standard EN 15234-1: 2011, ISO 9001: 2015 or EN ISO 17225-4: 2014or an equivalent standard
- All woodfuel must be certified by the Woodsure Certification Scheme or an equivalent certification scheme as meeting the standard
**Suspension of Fuel Quality Requirements for Wood Pellet Fuel Only
From 16th November 2022, the regulations will be suspended for a period of 1 year in respect of fuel quality requirements for wood pellets for use in biomass boilers where the owner receives RHI payments. This decision was deemed necessary by a global shortage of quality pellet supplies because of conflict between Russia and Ukraine.
The government will be working with the BSL administrator Woodsure to ensure these pellets are temporarily accepted on the list. Ofgem will also ensure that their compliance regime is adjusted to accommodate the changes.
RHI participants will still need to be aware of the requirements stated in their emissions certificate when sourcing fuel. A specific fuel may have been specified on the boiler emissions certificate to control smoke emissions. Use of other grades of fuel may adversely affect the operation of the appliance and may mean that the emissions requirements in the regulations are not met.
It is also important that boiler owners ensure that their specific appliance can tolerate any intended grade of fuel, so the equipment is not damaged. They will need consider any manufacturer warranty provisions.
General Compliance
To ensure the continued sustainability of the NDRHI scheme, Ofgem are endeavouring for all other regulations to be met such as biomass content/levels of contamination in fuel, relevant permitting and planning permission for boilers and more.
Do you have any concerns over these updates to RHI regulations? ECS can help.
ECS are in a valuable position to help with many years of experience liaising with Ofgem and resolving compliance issues within the NDRHI. Amy Fielding, founder of ECS has personally dealt with the scheme since it was first launched in 2011. The company also hold committee positions within the REA Wood Heat Forum Steering Group and the Woodsure (BSL) Fuel Quality and Waste Advisory Panel so are kept abreast of the latest industry knowledge. Furthermore, ECS work alongside a highly respected UKAS accredited laboratory which offers easy to access, quarterly fuel analysis to complement our RHI compliance services. This is a simple way to provide evidence to the regulator regarding the biogenic content/contamination within your fuel.
If you are not a participant of the NDRHI scheme or want to upgrade your current technology, you may want to explore acquiring RHI Tariffs. Or if you require general advice for the waste wood you produce, these are areas which we are also happy to assist with.
Please don’t hesitate to contact our policy and compliance coordinator milly@envirocompliant.co.uk with your query and we will aim to get back to you as soon as possible.
