Have you been approved for an RHI extension? Or maybe you are still waiting for your Tariff Guarantee Stage 2 to be approved? Both have completion deadlines of 31 March 2022, but do you have your permit prepared?
If you are installing combustion plants over 1 MWth, or operating on waste wood, you will need to submit evidence of an environmental permit for your full RHI application. At present, the Environment Agency have application queues of over 6 months (after submission) just to be allocated to a permitting officer, and Local Authorities require approximately 5 months to determine a permit (area dependant).
What does this mean for me?
If you have not started your permit application process yet, whether it’s because you did not know you needed one, or you are reluctant to start before your Tariff Guarantee is approved, the longer you leave it the more unlikely it is for you to have a permit determined, yet alone issued, before the 31 March 2022 deadline. This can directly impact your RHI application, so waiting “just in case you’re rejected” may be riskier than applying for your permit earlier.
What are the risks of applying now?
With regards to permit application fees, if you apply before Ofgem rejects your Stage 2 Tariff Guarantee, but work has not started on your permit, you can get most, if not all, of your application fee returned to you (cancellation policy dependant). However, if you have applied and Ofgem later award your Tariff Guarantee, then you will be much further ahead in the application process than if you had waited. The only fees you cannot get back are those from third party works, such as dispersion modelling and permit consultancy.
The difference in waiting to submit or only submitting a permit application following Ofgem’s decision could be the difference between a successful RHI application or an incomplete application in March 2022. RHI applications not properly are likely to result in rejection, which is much riskier than starting an application which you can withdraw at a later stage if needed – choose the lesser risk and apply for your permit as soon as your project allows!