Consultation question 1596 unique responses
Q25 Do you agree or disagree with the proposed reporting system to underpin sustainability criteria? Please provide your reasoning.
Summary of responses
Most of those who responded to this question said they were neither 5.15.
for nor against the proposal. Only approximately 10% of all respondents to the consultation expressed a strong opinion, the majority of those in favour of the proposal.
Agreement with proposal
Comments from respondents who agreed with the proposal included 5.16.
that it was a good idea to make FITs consistent with the RO and RHI schemes and to use a similar approach to reporting as those schemes. There was also agreement that smaller installations should have a reduced reporting burden.
Disagreement with proposal
Comments from those who disagreed included that sustainability 5.17.
criteria and reporting on them was restricting generators, farmers in
particular, from diversifying or innovating and that the market should decide the type of feedstocks used. Some respondents felt that AD needed time to bed in before introducing sustainability criteria. A few believed that the proposals were too onerous and should be simplified, whereas others suggested that the proposals did not go far enough.
Some comments queried whether FITs should introduce sustainability 5.18.
criteria at all since most plants were CHP and so already reported under the RHI’s sustainability criteria.
Suggestions were made to reduce the reporting burden on small-scale 5.19.
installations. These included that plants under 100kWe using a majority non- crop feedstock should be deemed to have met the sustainability criteria. Also, that crop feedstock sourced within a 25-mile radius should be deemed to meet the criteria. This would be similar to the RHI approach to deeming that generators sourcing solid biomass within a 50-mile radius were ‘self- suppliers’ and so do not need to report against the scheme’s sustainability criteria. There was also a request that the greenhouse gas emissions related to consignments of feedstock should be averaged.
There were a few conflicting views on whether auditing by Ofgem 5.20.
should apply to all plants regardless of size or whether reporting should apply to only large-scale plants.
Government decision
As stated in the consultation document, Government does not plan to 5.21.
introduce sustainability criteria immediately. However, Government remains committed to investigating the option of doing so. Therefore, DECC plans to set out further details as part of the AD tariff consultation that is intended to be launched early in 2016. The details will be developed in light of
stakeholder responses received to these questions.
Some of the comments and questions posed in stakeholders’ 5.22.
comments are addressed here. Some stakeholders questioned why
sustainability criteria should be introduced. There is a strong case to ensure that the FITs policy achieves significant greenhouse gas savings and
introduces minimum protections for land with a high ecological value. Not doing so could severely undermine the policy intent of delivering low carbon and sustainable energy. There are now a significant number of plants which use crops and these are set to increase. Without sustainability criteria, the risks only grow. Furthermore, with the RO and RHI schemes already having introduced sustainability criteria, Government will aim for a consistent
approach where practicable.
Regarding the use of feedstock from areas such as managed 5.23.
Renewable Energy Directive 200928 and place restrictions on sourcing feedstock from such areas. Similar criteria already apply under the RO scheme. Ofgem have produced RO guidance which provides further information on how they might apply in particular circumstances29.
On what the appropriate greenhouse gas saving threshold should be 5.24.
for AD under FITs (the consultation identified this as 60%), the greenhouse gas savings threshold under the RO and the RHI were informed by
recommendations from the European Commission30. The details of any threshold for AD under FITs would be set out in more detail in the proposed 2016 consultation mentioned above.
There was also a question about whether the 1MW threshold for when 5.25.
generators would have to conduct independent audits related to electricity generation (1MWe) or heat generation (1MWth). This would be confirmed in the planned detailed AD consultation.
28http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:140:0016:0062:EN:PDF 29
https://www.ofgem.gov.uk/environmental-programmes/renewables-obligation-ro/information-generators/biomass- sustainability-and-renewables-obligation
30 Report from the Commission to the Council and the European Parliament on sustainability requirements for the use of solid
and gaseous biomass sources in electricity, heating and cooling” (COM(2010)11), and the Commission staff working document (SWD(2014)259).
6. Administrative changes to the
Feed-in Tariff scheme
Government sought views on proposals to limit the type and amount of 6.1.
overseas renewable electricity that can be used for the purposes of claiming an exemption from suppliers’ shares of FITs costs, in line with the approach that has been implemented for the Contract for Difference Supplier
Obligation (CfD SO)31. Questions 26 and 27 were linked so the analysis of responses and decision are combined below.