How to comply with rule changes to keep biomass RHI payments

From this autumn, Renewable Heat Incentive (RHI) claimants must show that their fuel is sustainable.

Kevin Lindegaard, director of consultancy Crops for Energy and UK trade body the Wood Heat Association, explains what will be involved.

Complying with new fuel sustainability guidelines from 5 October this year will be more complicated and costly for hundreds of boiler owners using fuels such as straw and miscanthus, rather than the more common wood-based fuels.

The rules affect new applicants as well as the 10,408 existing biomass boiler installations covered by the Renewable Heat Incentive.

See also: Biomass boiler fuel tips – pellets v chips

The rules for woody fuels

Cut logs being loaded for chipping for use in a biomass boiler

©FLPA/Rex Shutterstock

For woody fuels – pellets, chips or logs, used in about 95% of RHI-accredited boiler projects – suppliers must register on the Biomass Suppliers List (BSL). Buyers, meanwhile, must ensure they source fuel from a BSL-registered company.

Those sourcing wood from their own woodlands or growing short-rotation coppice should also to register with the BSL. Each quarter they will then have to confirm their fuel is compliant, a process which takes less than an hour.

The rules for non-woody fuels

Straw bales

©Image Broker/Rex Shutterstock

There is no such list for the 300-500 projects using miscanthus and agricultural residues such as straw. Most of these are farm-based and many self-supply fuel produced on their own land.

Although inherently sustainable, these projects have to self-certify, which generally takes up to a day and a half of consultancy time.

Consultancies Crops for Energy and Farm Energy Centre have put a proposal to the Department of Energy & Climate Change (Decc) for a Waste, Residues & Energy Crops Sustainability List (WRECSL).

This industry-led scheme would be funded by an annual fee paid by participants based on the amount of fuel they produce or trade. If approved, it could be up and running by early 2016 and reduce the time needed to establish compliance to between one and two hours.

What all biomass fuel users must do now

In the meantime, all fuel users need to engage with the Ofgem process for reporting fuel sustainability as soon as possible to avoid any queries on a submission resulting in delayed or cancelled RHI payments.

Miscanthus in the mix

David Christopher, Langaller Farm, Somerset

Miscanthus chip storage at Langaller Farm

David Christopher runs a mixed farm which includes 40,000 indoor reared chickens on a two-month cycle and 15.4ha of miscanthus.

A 130kW Eta boiler is used to heat three poultry units and two houses and runs exclusively on miscanthus chip.

The system was accredited for the RHI in September 2012. The closest field is only 100m from the boiler whilst the furthest is less than 1km.

This set up will easily meet the sustainability criteria but getting all the paperwork assembled and analysis completed is likely to be time consuming and expensive. 

“Sustainability is really important but the bureaucratic requirements that need to be met are grossly disproportionate for my situation – it’s self-evident to anyone that this is highly sustainable,” says Mr Christopher.

 Simple guide to fuel sustainability requirements

Draft sustainability guidance has just been released by Ofgem instructing all participants of the RHI what they need to do to comply by 5 October

Woody biomass

Non-woody biomass, Biogas & Biomethane

There are three options:

Self-reporting is the only option for the time being – the following steps need to be completed by 5 October:

Use fuel listed on the Biomass Suppliers List

Calculate greenhouse gas emissions for fuel used each quarter 

Register as a self-supplier on the Biomass Suppliers List

Provide evidence that the land used to produce the biomass meets the land criteria, to ensure that the biomass has not been grown on protected land


Complete a Fuel Measurement and Sampling (FMS) questionnaire and agree procedures for this with Ofgem 


Installations larger than 1MW need to have an annual sustainability audit report by an independent third party


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