Independent review into fuel quality implementation

Renewable Energy Association undertake independent review of fuel quality implementation

In January 2021 fuel quality legislation was laid in Schedule 4A of the RHI regulations.  

Schedule 4A was intended to come into force on 1st April 2022 and cover the implementation of fuel quality standards for all biomass boilers participating in the Domestic and Non-Domestic RHI that are burning wood.   The fuel quality requirements were put into legislation by BEIS, enforced by Ofgem and impacted on suppliers and self suppliers alike.   Anyone claiming RHI payments needs to comply either with a BSL number or if a self reporter to Ofgem, evidence that they comply with the legislation.  

The new requirements were originally to come into force in April 2022. However, implementation was delayed until June 2022 due to it becoming clear that the industry was neither fully aware or prepared for them to come into effect.  

REA’s independent review seeks to identify what went wrong with Schedule 4A’s implementation, what went right – and to deliver recommendations for future implementation of similar regulations so that lessons can be learned from this experience. If you are interested in giving your opinion, we will be sharing a link to the REA stakeholders review in early 2023 and we will advise all BSL participants of this review.  

The REA is well placed to conduct this review as the Biomass Heat industry trade body and an independent observer to the implementation of the scheme.

BSL Quarterly Newsletter | December 2022

This year and last have been significant years in the recent history of the BSL service and many of you will have experienced the highs and lows of this. With this in mind I wanted to share with you a ‘behind the scenes’ view about what’s been happening and how it all went.  The first was the contract transfer from Gemserv to Woodsure and the second was 

First a little context, in case you do not know.  The BSL Advisory panel is made up of BSL members like yourselves, voted in by you. It meets quarterly to advise the BSL service and the government department BEIS on the day to day experience of members of the service, to ensure value for money for members and to provide member input to new developments and initiatives. 

Contract Transition

Last year if you recall the contract to manage the BSL service changed hands from a company called Gemserv and was awarded to Woodsure part of Hetas.  The transition happened in the summer of last year and for intents and purposes went very smoothly, however much like to proverbial swan gliding elegantly across the water, there was a lot of frantic paddling underneath to make it all work. 

A lot of work was needed to transfer all the IT systems and data (what you see as the BSL website) to the new organisation as well as all the call handling systems and processes.  While Gemserv were extremely helpful with the transfer, much of this was new to the Woodsure team and getting to grips with the old system and ensuring that it ran on Woodsure’s platforms was not as straight forward as everyone would have liked.  That said, Woodsure burned the candle at both ends to make this happen and both the IT and the call handling the systems were up and running seamlessly at the point of transition. 

The good news is that Woodsure has just upgraded to a new portal and whilst there are still a few teething issues due to the extremely complex nature of the website, these should diminish over time.   

Implementing the New Quality Laws

As you know this year saw the implementation of the government’s new fuel quality legislation which required that all biomass fuels sold to RHI supported boilers must be of an appropriate quality standard to remain accredited with a BSL number. This was the most significant development in the BSL service since its inception, impacting over 4,000 suppliers and 7,500 fuels.  

Planning for this this started last year. The aim was clear – to ensure that every BSL Supplier was given fair and reasonable opportunity to comply by the deadline of the 1st April 2022 and that end users would not be adversely impacted. The project team was well staffed with “surge” capacity from the both the extended Woodsure and Hetas teams to help if needed. 

Implementation began in January with emails going out and to inform suppliers of the deadline and what the new law required for suppliers to be ready by April 1st 2022. 

There were several challenges the team had to overcome to get this over the line.  

  • Interpretation of the new legal requirements and how to implement them was still being refined during the implementation period. Any new interpretations needed to be agreed by BEIS and Ofgem before updated information could be issued leading to delays in responses and new FAQ’s.
  • The complexity of larger applications increased the time taken to process and meet deadline.
  • The large volume of work which needed to be handled in a short period of time and the number of consultancies offering fuel quality certification services delaying the quality assurance process and registration.  
  • The Ukraine war and the removal of Russian sourced fuels added a complexity that has not been planned for. 
  • A COVID outbreak in the Woodsure/HETAS team which took out 50% of the workforce for 2-3 weeks.
  • Severe difficulties in recruiting new staff as experienced by many businesses over this period.

That said the single biggest challenge was to encourage us as members to take action! 

In an ideal world the applications to get BSL fuels assessed for quality and registered as such would have happened evenly with steady stream of applications over the 2 months implementation period keeping staff busy but not overwhelmed.  This was not to be!

In spite of 9 communications between the 24th of January and 25th March using a variety of different media (email, SMS messaging, the website and physical letters in the post) only 40% of suppliers had taken any action by a week before the deadline.  In some cases, this was due to contact details being out of date or companies having changed name since registration, but mostly we seemed to be pre-occupied by other priorities.  

When we as members did take action it seems we all did so at the same time, overwhelming the BSL helpdesk and the Woodsure and ENplus quality assurance teams. To illustrate, the communications which got the most traction were the physical letter sent out on January 24th and the BSL number suspension email sent out on the 25th March.  The former resulted in 1,700 calls and 554 emails in the last week of January and the first couple of weeks of February.   The later resulted in 3,192 calls and 576 emails in late March and early April. It is this which precipitated the extension for compliance until 1St June 2022.

As with all big projects there are several lessons we can learn from this and these will be captured in a review later in the year. There have also been a number of benefits including a measurable increase in understanding of what biomass fuel quality means and in the quality of fuels provided under the scheme which was a critical objective for the legislation. 

Overall from January to June the BSL helpdesk team dealt with over 6,000 telephone enquiries and 4,000 emails, while simultaneously Woodsure were processing over 3000 fuel quality applications to be cross referenced back into the BSL portal. 1,210 fuels were removed from the BSL mostly for not demonstrating and fuel quality (702) or for non-payment (412).   As of May this year the BSL had 6,360 fuels registered and 3,829 suppliers fully accredited for fuel quality, with just 340 fuels and 320 suppliers still in progress.   

Self-supplier viewpoint

Letter from Ross Lowrie, Advisory Panel representative for Self Suppliers.

To introduce myself, I’m a climate change policy advisor who lives in a small Northumberland woodland and grows, cuts, splits and dries my own biomass for use in my ETA log boiler. I’m a passionate advocate for sustainable woodland management and low carbon solutions to tackle the increasingly urgent climate change challenge. For the last 7 years I’ve benefitted from Domestic RHI payments, and government has benefitted from my small contribution to decarbonisation of heating. I’ve gone down the biomass route because it works for me and my family, and because there’s a comforting simplicity to the supply chain given global fuel security issues. It’s no longer than the height of one of my over-grown pines. The northerner in me is drawn to the old adage that “he is twice warmed who cuts his own wood”. If you’re also registered as Self-Supplier under the Biomass Supplier List and a recipient of domestic or non-domestic RHI then I represent your views on the BSL Advisory Panel, and you may understand some of the irks that I set out below. 

The introduction of new Regulations in England insisting that recipients of Renewable Heat Incentive grant money demonstrate adherence to fuel quality requirements has been challenging. The intent of the Regulations is to reduce particulate emissions into our atmosphere and dry, good quality biomass fuels help achieve this. For self-suppliers of woodfuel, there have been particular challenges. Many of us are small scale woodlanders, most likely not full-time foresters, even less so full-time bureaucrats. In fact, we’re defined by not selling our wood-fuel, rather we simply process enough for our own self supply, whether that be for domestic or commercial use.  We keep the quality high because if we break our biomass boilers, we get the bill to repair them. 

Recent changes to the RHI Regulations mean we now need to demonstrate that we use good quality fuel by registering with Woodsure (or an equivalent scheme). 

This sits alongside a need to register fuels with the Biomass Suppliers List (BSL – a sustainability scheme), so at the moment we have to join two schemes, something that Woodsure wants to change and proposes a single scheme (or equivalents) for the future, to reduces costs and burden on the sector. 

Joining these schemes involves application form and the inevitable fee for handling it.  Then there’s the sending of a sample to Tewkesbury for testing and verification that the fuel is dry and not contaminated. It also takes us time to fill in forms that could be spent running a business, swinging an axe or when all else is done, enjoying our woodlands. 

This requirement for fuel quality systems and protocols and demonstration of sustainability is much needed and very sensible and proportionate for commercial woodfuel merchants – but in my view the requirement for self-suppliers must be kept as simple and cost effective as ever possible. 

I suggest that all I need to ensure the right quality is an axe and a moisture meter, all else is a distraction. Woodsure reports that their audits and testing demonstrate that not all self-suppliers find it so straight-forward and that test results demonstrate the ongoing need for some suppliers to persist and improve the quality of their fuel. 

For me there is no prospect of chemically contaminated or tropical rainforest sourced pellets entering my supply chain, and the enormous contentment of knowing that is hard to overstate. I know I’m “doing the right thing” and I think we need a system that recognises the low risk nature of self-suppliers.  I accept that it may not be the same for everyone, and I want to hear from you about your views of being a self-supplier, particularly in relation to fuel quality requirements, so please lend me your voice.   I’ll represent your views and pass them on to the BSL Advisory Panel and Woodsure.