Sustainability Criteria

Demonstrating compliance with sustainability criteria is mandatory for operators using the Renewable Obligaiton or the Renewable Heat Incentive. Operators must report evidence on land use and greenhouse gas (GHG) emissions for crop feedstocks, and demonstrate that this is compliant with limits set out by BEIS (formerly DECC).

Proposals in the 2016 consultation on the Feed-in Tariff include introducing a sustainability criteria. If implemented the proposal will affect any new FIT installation from January 2017, but will not be applied to existing projects. Further details of the government proposals are detailed below.

The development of the land and GHG criteria across UK renewnable financial incentives comes from the requirements imposed by the European Community via the Renewable Energy Directive (RED). The RED sets out the sustainability criteria a bioliquid must meet in order to receive support under national incentive schemes. Following the release of the RED the UK Government also released the Bioenergy Strategy which explains the approach taken to secure the benefits of bioenergy. The strategy is likely to be revised in 2017, at which point sustainability criteria could be further revised.

Since the release of both the RED and the Bioenergy Strategy we have followed this up with the lauch of crop best practice guidance - agreed with government - which can be found by clicking here.

If you have any queries regarding sustainability criteria email Thom Koller or Ollie More. 

Key Links

RHI

The sustainability criteria for the RHI came into affect from October 2015 and all plants (existing and new) must now comply. Proposals were summarised in a briefing note from DECC.

  • GHG

Solid biomass or biogas/biomethane has to achieve 60% GHG savings compared to the GHG emissions of the EU fossil heat average; this equates to lifecycle emissions of less than or equal to 125.28kg CO2 equivalent per MWh of biomass heat generated. 

  • Land Use

​For feedstocks, the land criteria corresponds to those set under the RED for transport biofuels and bioliquids. These criteria consists of general restrictions on the use of biomass sourced land with high biodiversity of high carbon stock value such as primary forest, peatland and wetland. 

  • Reporting

​Operators need to "declare on a quarterly basis that their fuel complies with the sustainability criteria and produce and submit an annual report to Ofgem", covering both the GHG target and the land criteria. The Ofgem carbon calculator can be used to demonstrate GHG emissions, but operators are free to use other methods if they wish, as long as they follow the approach for calculating life set out in the RED.

RO

As of April 2015 the RO sustainability standards consist of two criteria:

  • GHG

​Operators over 1MW will need to meet the below emissions criteria from 2015. The trajectory of these criteria will not change until April 2027 unless European or international legislation forces an amendment:

* April 2014 - March 2020 = 285kg CO2eq/MWh

* April 2020 - March 2025 = 200kg CO2eq/MWh

* April 2025 - March 2030 = 180kg CO2eq/MWh

  • Land Use

​General restrictions on the use of biomass sourced from land with high biodiversity or high carbon stock value such as primary forest, peatland or wetland and will have to be met by April 2015

Operators using energy crops will be required to provide detail on the previous use of land as part of the profiling data requirement.

  • Reporting

​Annual Sustainability Report - The report should contain profiling information regarding the sustainability characteristics of their fuel such as: type of biomass, country of origin and whether it conforms to any environmental quality assurance standards.

Land use and GHG emissions - This information should be provided on a monthly basis as part of each ROC claim. For bioliquids both the land and GHG criteria must be met to be eligible for support.

FIT

BEIS (formally DECC) launched their consultation on changes to the Feed-in Tariff for AD plants on 26 May 2016. This follows the review of the Feed-in Tariffs for all technologies conducted last year, which deferred questions on AD tariffs and feedstock rules until this consultation.

The consultation also contained proposals to introduce sustainability criteria for the FIT scheme. This will include land criteria and greenhouse gas emission limits for anaerobic digestion. If implemented the proposal will affect any new FIT installation from January 2017, but will not be applied to existing projects. The sustainabiltiy criteria proposals are as follows:

  • Land use

Biomass must not be sourced from land with high biodiversity value, including, primary forests, grasslands and of areas designed by law for nature conservation purposes.

Biomass must not be sourced from land with a high carbon stock value, including wetlands, continuously forested areas or peatlands.

  • GHG

Greenhouse gas emissions from AD installations would have to fall below: 66.7gCO2e/MJ from after 1 April 2013; 55.6 gCO2e/MJ from 1 April 2020 – 31 March 2025; and 50.0 gCO2e/MJ from 1 April 2025 onwards.

If this proposal is implemented, new AD installations must comply with the following actions to receive FIT payment for generation and export:

  • Quarterly reporting to Ofgem including a declaration as to whether consignments of fuel used is from waste or derived from waste.
  • If it was not waste or derived from waste, there must be a declaration as to whether consignments met the land criteria and the RO GHG emissions limits, which should meet the emissions figures.
  • This must be provided within 28 days of the quarter in question.
  • Annual independent audit report for installations 1MW (electrical) or above, which must be submitted to Ofgem within 3 months of the first anniversary of eligibility date that falls after the ROOFIT accreditation.

Members can stay in touch with any devloping news on this consultation by reading recent blogs on FIT

Future policy

While sustainability is hugely important, according to the EU a number of biomass pathways may lead to negligible or negative GHG savings or other sustainability impacts. Further research and analysis is therefore needed to assess the future role of such pathways in the EU energy sector and to gain better information on overall biomass availability for the EU in the period post-2020.

Biomethane Issues

A number of issues have been raised about how best to assess GHG savings associated with biomethane production and use. In particular an EC 'state of play' publication on solid and gaseous biomass sustainability suggests a good practice standard of 70% GHG savings against a natural gas comparator. This would equate to 78kg CO2e/MWh of biomethane injected into the grid.

BEIS therefore intend to work with industry to further develop the RHI sustainability policy for biomethane plants supported under the RHI.