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. 

Scams | Fraudulent Certificates and fake websites

The following information has been developed and distributed by the UK Pellet Council.

Please be aware that there are currently numerous fraudulent certificates in circulation across Europe that are being presented to potential customers, including certified Traders, as evidence that the product they are purporting to sell is ENplus® certified. The certificates look authentic and appear to be issued by approved certification bodies but usually contain an ENplus® ID that belongs to an entirely different company.

It is recommend that you check the validity of any company that presents themselves as certified on the ENplus® website (click here for Producers and here for Traders) or forward a copy of the certificate and other supporting evidence to mstafford@pelletcouncil.org.uk for verification. In particular over recent weeks there has been a high number of companies offering pellets apparently produced in Turkey. There is only one active ENplus certified company in Turkey. The high tonnages of pellets being offered strongly suggests that much of the supply is in fact sanctioned Russian product and should be avoided.

The UKPC and wider ENplus®Management has also been inundated with reports of fake websites offering ENplus® wood pellets for sale, often at substantially discounted prices using well-known brand names. These websites are sometimes cloned from an existing website –not necessarily that of a wood pellet supplier –but crucially use the correct company name, address andENplus® Quality Seal of a certified Producer or Trader. We are currently aware of four such sites that have ‘offered’ UK-manufactured product for sale, two of which have impersonated the domain names of certified UK Producers by altering a couple of letters. To all intents and purposes these sites appear to be those of ENplus® certified companies selling ENplus® certified product.We would like to offer the following advice to our member companies:

  1. If you have an official website please provide us with the details, if you haven’t already done so, in order that we can add the details on the ENplus® and UKPC websites
  2. If you don’t have an official website please provide us with your permission to add your preferred email for sales. This will help customers get in touch with you directly and avoid scammers
  3. Publish information on your own website describing the dangers and encouraging vigilance and, if you have a database of customers, please warn them via email about potential scam practices
  4. If you have spotted a fake website that is either imitating your company or offering products for sale without your permission then there are a number of steps that you can take, including the following:
    • Emailing the site’s administrators, report the site to ICANN, contacting Google to de-index the site from search engines and contacting the service provider (the host or the CMS platform) who may be able to simply take the site down. A number of these points are addressed in a (sponsored) article at https://www.redpoints.com/blog/how-to-take-down-a-fake-website
    • If the website is fraudulently acting as another business andtaking payments then report it to the police online athttps://www.actionfraud.police.uk/reporting-fraud-and-cyber-crime
    • Contact mstafford@pelletcouncil.org.uk to provide you with the information that has been shared with me by our member companies who have been involved in combatting these scams

The UKPC would like to offer the following advice to customers(see 3 above)

  1. Always check your supplier contact details (website/email) against the list of certified companies on the UKPC website at http://www.pelletcouncil.org.uk/enplus-traders/or http://www.pelletcouncil.org.uk/consumer-information/enplus-producers/and/or on theENplus® website at https://enplus-pellets.eu/en-in/certifications-en-in/trader-en-in.htmlorhttps://enplus-pellets.eu/en-in/certifications-en-in/producer-en-in.html
  2. Don’t pay upfront to unknown suppliers
  3. If the price of the pellets seems too good to be true it almost certainly is!
  4. Be aware of falsified invoices with a replaced bank account as, sometimes, fraudsters use old invoices of the real supplier by simply replacing the bank account details
  5. Check the approved bag designs of the certified company on either the UKPC website and/or the ENplus® website down to the very last detail to be sure you are buying certified pellets. Some fraudsters will try to confuse you by replicating almost entirely the bag design of a certified producer or trader
  6. In case of doubt that you are not communicating with a real certified company, please forward your correspondenceto mstafford@pelletcouncil.org.ukso that the UKPCcan check and verify the identity of the company

In summary, please act with caution if you are considering buying wood pellets from a company you have not previously dealt with, and please communicate to your customersthat they should exercise caution too.

RHI Biomass Fuel Guidance – suspension of fuel quality requirements for wood pellet fuel only  

Background

UK Statutory Instrument2022 No. 159 

ENERGYThe Domestic Renewable Heat Incentive Scheme and Renewable Heat Incentive Scheme (Amendment) Regulations 2022 

Please be aware that the Government has introduced a suspension of fuel quality for pellets only and came into force 23rd November 2022 for a period of up to 1 year.   This means that the fuel quality requirements for wood pellets for use in biomass boilers and plant where the owner receives Renewable Heat Incentive payments via OFGEM are not required while this suspension is in effect. 

In February 2022 Government introduced amended regulation requiring that any wood fuel with a Biomass Suppliers List (BSL) number must also meet the relevant quality standards as described in Regulation 4.  

Following an appropriate consultation process, made necessary by a global shortage of quality pellet supplies because of conflict between Russia and Ukraine, the UK Government published its response which concluded: 

We are grateful for the valuable responses to this consultation. The government now plans to implement a 12-month suspension to the fuel quality requirement for RHI participants using wood pellets specified in Schedule 4A, paragraph 2. We are confident that a 12-month suspension strikes the right balance to make additional supplies of wood pellets available for this winter. In turn it should also serve to mitigate against potential price rises due to a lack of supply. 

This temporary suspension will be enacted through secondary legislation and will apply to both the non-domestic and domestic RHI schemes. We will work with the Biomass Suppliers List (BSL) administrator to ensure that these pellets can be temporarily accepted on the List subject to compliance with other requirements. We will work with Ofgem to ensure that their compliance regime is adjusted to reflect the changes. We will work with Ofgem to update guidance for participants to be aware of the requirements stated in their emissions certificate when sourcing fuel. 

Additionally, we are considering bringing forward secondary legislation to give the Secretary of State the power to temporarily suspend the requirement for domestic and non-domestic RHI participants to use ENplus certified pellets. This power could be used in situations of a shortage of wood pellets in the domestic market, with agreement across government. Our commitments to improve fuel efficiency and air quality remain; therefore, ahead of using such power, we will engage with the biomass industry and consider potential impacts on air quality and fuel efficiency.” 

How does this affect pellet suppliers? 

The Government has introduced a suspension of fuel quality for pellets from 23rd November 2022 for a period of up to 1 year.  During this period, fuel suppliers will be able to register wood pellets on the BSL that meet the sustainability criteria but are exempt from the fuel quality requirements. Suppliers are encouraged to ensure that fuel quality remains an important consideration and they provide all relevant information to their customers to enable them to make an informed choice with regards what pellets their boiler can operate on and whether they may or may not have any issues.

How does this affect RHI participants? 

Fuel quality remains an important consideration for purchasers of pellet fuels for biomass boilers and plant.  

Boiler operation and efficiency 

Many smaller boilers in particular, rely heavily on the continued use of a specific grade or type of pellets specified by the boiler manufacturer and/or for effective and efficient operation. There may be manufacturers warrantee conditions for boilers under guarantee, where use of a specific fuel type is specified. 

Boiler emissions certificate 

As part of the RHI and NDRI approval process a specific fuel may have been specified on the boiler emissions certificate to control smoke emissions. Use of other grades of fuel may adversely affect the operation of the appliance and may mean that the emissions requirements in the Regulations are not met. See OFGEM Guidance as they are the Administrators of the financial incentive aspect of RHI.  

Larger boilers 

It is important to consider any fuel quality issues and warrantee provisions etc. Although many larger appliances and plant may tolerate a wider range of pellet grades, it is important to get appropriate specialist advice to be sure that your specific appliance can tolerate any intended grade of fuel.  

BSL Search 

Changes have been implemented to the BSL website to remove reference to fuel quality when searching for wood pellets. Following the suspension period, these references will be added back on to the website. 

It is hoped that operators choose appropriate fuels for their circumstances in the hope that if there are winter shortages there are appropriate quality pellets available in the market for those whose boilers need them.  

The full government consultation response can be viewed here.