Green gas support scheme
Tuesday 25th of May 2021 | Posted In: Generate, Comply

Regulator site audits – are you compliant?

Do you have an RHI, FiT, or ROC accreditation? Are you a recognised supplier of biomass fuels on the Biomass Suppliers List (BSL) or the Sustainable Fuel Register (SFR)? Or do you operate an Anaerobic Digester that provides biomethane or exports electricity to the national grids? If so, you may be subject to an audit from any of a number of regulators and governmental bodies – NFU Energy are here to help!

Site audits are on the rise now that COVID-19 restrictions are starting to ease and since the closure of the RHI scheme. We have seen an increase in NFU members asking for help with combustion plant environmental compliance evidence, requested by Ofgem during or after an audit. Our compliance assessment service will help you understand what environmental compliance is required for your site, if any, and when. We can support you in obtaining written confirmation from the appropriate Regulator that a permit is not required until a later date, or if an exemption is applicable. We also offer an RHI HealthCheck service, where we will come to your site and talk you through what to expect from the audit, what paperwork and record evidence will be required, and assist you with any queries or concerns you may have in advance.

When it comes to BSL and SFR companies producing fuel for combustion, they may not be aware of the environmental compliance requirements for larger fuel suppliers, especially if operations exceed a throughput of 1000 m3/yr of biomass product. Guidance note PGN6/02 was last updated in 2012 but states that wood and waste wood sites exceeding 1,000 m3/yr of product (10,000 m3/yr of produce for sawmills sawing wood only) are required to have a permit to operate. Waste operators may be eligible for exemptions with the Environment Agency, depending on their activities, commercial services, and capacities. Our compliance team can help determine what is required for your company and ensure you are operating legally.

Anaerobic digestion plants have also seen a surge in audits from both Ofgem (for biomethane and electricity export to grid) and Environmental Regulators. Sites processing purpose-grown crops and no waste feedstocks are exempt from environmental permitting for both the operation of the non-waste digester and storage/use of its digestate. However, if you utilise any animal wastes or residues, or import wastes from suppliers, you will require a waste operate permit. Sites within specific thresholds may also be applicable for permit exemptions, or standard rule permits, which NFU Energy can also assist with. Some exemptions include the use of biogas combustion plants of less than 400 kW thermal input, which allows their operation without additional permits. Plants over this size, with grid export, or over 1 MWth input may require permitting as a Specific Generator with the Environment Agency.

If you need help an RHI audit, permit applications and variations, regulatory compliance registration, or procurement of a permit exemption statement, please call us on 024 7669 6512 and stay up to date with the latest compliance news at www.nfuenergy.co.uk