RHI Sustainability Criteria & The Sustainability Audit

Transcription

1 UK Biomethane Day 2014 RHI Sustainability Criteria & The Sustainability Audit Introducing the forthcoming legislation affecting most bioenergy projects receiving Government support

2 UK Biomethane Day 2014 Paul Adams Director, Synertree Ltd +44 (0) PhD in Mech Eng life cycle assessment of bioenergy (2007) - GHG reporting & auditing in the UK & Australia - 5 years at PriceWaterhouseCoopers auditing and modelling (non-financial & financial)

3 Sustainability Criteria Key Points RO RHI FIT GHG criteria April 2014 Land criteria April 2015 GHG criteria Oct 2014 Land criteria April 2015 No current proposals Likely to change in future Installations over 1MWth, will have to use the actual value method of reporting. Default values used below 1MW Default values used below 1MW 2015 consultation Audit threshold is not clear (possibly 1MWth but could be less)

4 Sustainability Criteria: GHG limits on fossil criteria: EU heat RHI: kg CO 2 eq per MWh [RO: 285kg CO 2 eq per MWh (to 2020)] All consignments of feedstock must meet these limits Demonstrating compliance Operator can choose how to demonstrate compliance, either BCC or own models Ofgem provides the Solid and Gaseous Biomass Carbon Calculator as a tool Includes default values but gives opportunity to edit these for individual sites If using own model this must follow the methodology government sets out and use the standard emission and conversion factors

5 What does 34.8gCO 2 eq/ MJ biomethane consist of? Cultivation & Harvesting - Fertiliser Production (N fertiliser 150kg 5-7gCO 2 e N 2 O emissions from soil of 6-8gCO 2 e. - Diesel consumption also important Collection & Transport - Impact depends on logistics - Unlikely to be significant Default value is 0.2g CH 4 / MJ Output ~1% loss 5gCO 2 e (x 1.4?) Upgrading & Injection AD Facility Operation

6 Sustainability Criteria: Land Use Corresponds to the land criteria set out in the EU Renewable Energy Directive for transport biofuels and bioliquids was primary forest, or a continually or lightly forested area was land designated for nature protection purposes Land use shouldn t be an issue for existing agricultural land Biomass cannot be sourced from land which at any time since January 2008: Wastes are exempt, residues need to report on land criteria was wetland (unless that land is still a wetland) was peatland (unless this did not involve the drainage of undrained soil) Where land use is changed in a permitted way, a carbon stock calculation resulting from the land-use change will need to be performed Operator will need to consider which category land has fallen in since 2008, and provide some form of evidence on this

7 Future of Sustainability Criteria RO Grandfathered for individual sites from point of accreditation RO shuts to new projects from 2017 RHI Not grandfathered for individual projects, as was originally intended! DECC will review criteria every three years, so criteria could be changed in 2017 for implementation in 2018 DECC expect changes to be incremental unless new EU legislation forces further changes This is causing uncertainty for developers and there is lobbying to DECC to reconsider. FIT Sustainability criteria likely to be considered again in 2015 review?

8 Sustainability Criteria: Guidance Renewables Obligation Draft guidance published on 1 st April 2014 Synertree, Future Biogas, REA, ADBA, and various others responded to this consultation. Renewable Heat Incentive Limited information in main Ofgem RHI guidance Would expect this to be developed as criteria come in. Hopefully this will be soon!! Likely to follow similar structure as RO (i.e. DECC intends to ensure consistency across reporting schemes) Until Guidance on RHI is issued there remains several uncertainties, e.g. mass balance, allocation, methane slip, thresholds, etc.

9 Biomass Carbon Calculator Background Developed by E4tech on behalf of DECC to help demonstrate compliance with sustainability criteria Available for operators to download from the Ofgem website How it works Operator creates pathways for different feedstocks Default values available; operator can vary these but will need to provide evidence e.g. for lower fertiliser use or transport emissions Default values tend to be conservative, partly to encourage reporting of actual figures

10 Biomass Carbon Calculator

11 Biomass Carbon Calculator Revision process First stage of revisions (for woody biomass) coming to end DECC allocating resources to update biogas and include RHI technologies such as biomethane Process underway to conclude over next few months Stakeholders working with DECC and E4Tech to resolve these issues Our key issues Clarifying the approach for apportioning emissions to different feedstocks within the consignment Providing a more accurate figure for fugitive methane emissions, and clear guidance on how operators can vary this. A clear approach for apportioning emissions to digestate as a co-product Allowing a wider selection of potential feedstocks

12 Indirect Land Use Change Current approach Emissions from ILUC not generally considered at present Pressure from NGOs and others to include DECC work (BEaC Calculator) underway Future Expect it to be included at some point Could have a serious impact on reported GHG emissions for bioenergy Approach for AD very unclear DECC have recognised issues are different to those for other forms of bioenergy following input/meetings 2017 UK Bioenergy Strategy review could consider this further

13 The Sustainability Audit Likely to be required for all operators of a certain size (1MW th?) Must have an audit report prepared by a person independent to the operating station Undertaken in accordance with ISAE 3000 (limited assurance) It is the responsibility of the operator of the generating station to provide Ofgem with an annual sustainability audit report (probably < 3 months of reporting year-end) ISAE 3000 is for non-financial assurance and not limited to sustainability reporting The standard is therefore sparse on the detail that may help operators and verifiers! Auditor responsible for performing audit, but operator responsible for appointing relevant and competent auditor and agreeing scope of work. Operator should ensure that they fully understand the requirements of ISAE Be prepared!

14 Preparing for Reporting & Audit Seek professional advice/support if you are unfamiliar with GHG reporting Make sure that you allow enough time to implement appropriate measurement, information and documentation systems (if October start, then think about crops used!) Develop the audit trail from field to facility, from biomass to biomethane! Be familiar with the Ofgem requirements Appoint an auditor early as you will want to work with them through the year! Take this seriously as non-compliance will result in reduced RHI payments Be aware that adding waste feedstocks is not necessarily a solution as reporting is on a per consignment basis! Biomass Sustainability Criteria is here to stay, so you need to understand the potential implications for your facility and keep up to date with legislation. Be prepared!

15 UK Biomethane Day 2014 Paul Adams Director, Synertree Ltd +44 (0)