Common errors in applications for the Non
Domestic RHI
Tom Crawford
19/06/2014
Principles for you and your customers
Accreditation involves meeting a number of eligibility criteria, which must be
verified by Ofgem
•
To ensure this can be achieved readily:
• Understand the RHI eligibility requirements
• Plan for the RHI requirements as part of the design and installation process
• Obtain and retain documentation from manufacturers and installers
• Complete the application fully, with the correct evidence and level of detail,
seeking support from a third party (e.g. installer) if appropriate
•
Ofgem can help – Enquiry service, Easy Guides, Comprehensive Guidance by
Topic, Summary Applicant Guidance Notes
2
Common areas needing clarification
Main categories identified at review stage and at audit:
•
System capacity
•
Metering eligibility/installation (Class 2 heat meter)
•
Eligibility of heat use
•
Metering arrangements
•
Heat loss assessments
•
Emissions certificates
•
Letters of Authorisation (LoA)
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More frequent errors
1) System capacity
Conflicting information between the capacities of the name plate, air
quality certificate, commissioning certificate and IRMA report.
2) Metering eligibility/installation
Wrong orientation and other meter installation issues; location incorrect;
no evidence provided for a ‘class 2 heat meter’.
3) Eligibility of heat use
Building not wholly enclosed
4) Metering arrangement
Ineligible heat uses in the system not identified
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System Capacity and Commissioning
Information
Question
Do
Avoid
Installation
capacity (HA120)
•Support this with a clear photo of
boiler nameplate displaying capacity
and serial number
•Clarify this where this may appear
inconsistent with other sources (e.g.
where boiler model name e.g. ‘XX
200’ does not match nameplate
capacity e.g. 199kW
•Inconsistency with boiler plate, IRMA,
Commissioning Certificate, Emissions
Certificate
•Using a non-peak capacity (e.g. if boiler
is 195kW with chip, 220kW with pellet,
we must consider as 220kW
•Wrong units (W or MW or btu etc))
Commissioning
date (HC110)
•Support this with a commissioning
report - or where this is not
possible, provide a case with
invoices and photos to demonstrate
plant was not commissioned prior to
the relevant date (often 15 July
2009).
•Inconsistency with commissioning
report, invoices, IRMA, meter readings
and dates
•Providing installation date rather than
commissioning date
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System Capacity and Commissioning
Information
Question
Do
Replaced plant
(HJ170)
•Provide details for plant
removed from the system
•If these are the same
technology, give a clear
statement that all integral
equipment has been replaced
and is new – and attach
evidence to support this (e.g.
an invoice)
Description of
installation
(HK120)
•Give a comprehensive
description
Avoid
•Including plant still connected to
the system – these are described
elsewhere in the application
•Including decentralised or isolated
plant
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Emissions Certificates
Question
Do
Avoid
Certificate
upload (HL121)
•Upload a certificate in the
latest Ofgem format where
possible, which matches make,
model, and capacity of the
installation (or its constituent
plant)
•Certificates not in line with the
type testing range
PM and NOx
emissions
values (HG121125)
•Ensure these match the
emissions certificate values
•Inconsistency with the values on
the certificate
Fuel type and
moisture
content
•Ensure the tested fuel type is
consistent with the fuel type
and moisture content that will
be burned
•Using a certificate for a standard
fuel type where a non-standard or
contaminated fuel will be used
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Air Quality and Moisture Content
Edmund Ward
19/06/2014
8
A. Background and policy intent
B. The air quality requirements
C. December amendment
D. Experience so far
E. Where we are now
F. Advice for completing certificates
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Air Quality - Background
• The RHI is incentivising the burning of biomass which means there will be an increase
in pollutants
• The intention to introduce air quality standards has been in the public domain since
March 2011.
• The biomass tariff takes into account the cost of abatement
• After the regulations completed their passage through Parliament in July they came
into force on 24th September 2013 following stakeholder feedback not to introduce
these requirements early.
• All biomass boilers affected for applications that submit from 24th September
onwards (unless a preliminary accreditation was received before this date)
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Policy Intent
• Limit pollutants to reduce the impact on air quality
• Ensure evidence provided for emissions is robust
• Monitor actual emissions to feed into assessment of suitable limits
• Ensure that participants continue to remain within the emission limits by placing
obligations on fuel use, regarding type and moisture content
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Air Quality – what are the requirements
• Imposes limits on levels of pollutants – 150g/GJ oxides of nitrogen (NOx) and 30g/GJ
particulate matter (PM)
• Evidence required for accreditation is either a RHI emission certificate or an
environmental permit
• An RHI emission certificate must be issued by a testing laboratory and contain all the
information specified in the template
• Ongoing obligations are to only use the fuel types and fuel moisture contents
permitted on the emission certificate, and operate the boiler in accordance with
manufacturer’s instructions in relation to the control of PM and NOx emissions
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Working with applicants, manufacturers
and test labs
• Applicants simply want a certificate with all the information provided and suitable
permitted fuels
• We’re keen to work closely with manufacturers and test labs to ensure the
requirements are understood
• Reduction in processing time for applicants
• More certificates ‘right first time’
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The December amendment
• Received feedback from industry that some of the requirements were very difficult to
comply with for boilers 500kW and under
• Confirmation that testing was carried out in accordance with BS EN 14792:2005 in
respect of NOx and BS EN 13284-1:2002 or BS ISO 9096:2003 in respect of PM
• Regulations amended and came into force 13th December 2013
• now, either comply with EN 303-5, or:
(i) testing was carried out in accordance with:
- EN 14792:2005 in respect of NOx emissions, and;
- EN 13284-1:2002 or ISO 9096:2003 in respect of PM emissions3; and
(ii) emissions of PM represent the average of at least three measurements of emissions of
PM, each of at least 30 minutes duration; and
(iii) the value for NOx emissions is derived from the average of measurements made
throughout the PM emission tests.
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Air Quality – December 2013 amendment
• If the new certificate template is used (v2.1 or v2.2) then either 4a or 4b must be
confirmed.
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Air Quality – December 2013 amendment
• If the original template is used (v1.0), we need confirmation of either:
• 4a
• 4b + 4d
• 4c + 4d
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

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Air Quality – December 2013 amendment
How do we treat affected* applications now?
• If 4a is confirmed and 4d states ‘no’ (or anything else), the applicant must provide
new meter readings from 13th Dec onwards
• 4d states ‘yes’ or ‘yes (basically applied)’. The applicant can choose between:
• Providing a test lab statement and keeping original effective date
• Not providing a test lab statement and providing meter readings from 13th Dec
onwards
• It doesn’t matter how long it takes to provide a certificate with all aspects verified,
the effective date can still be from 13/12/2013 for affected applications – or
submission date for non-affected applications – as long as it was a properly made
application
* ‘affected’ = boiler of 500kW and under, and submitted before 13/12/2013
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Experience so far
•
Some statistics:
– Over 1100 biomass applications submitted since 24/09/13
– 382 unique certificates
– Issued by 30 different test labs
– 63 different boiler manufacturers
– 124 certificates definitely affected by drafting error
– 155 certificates not affected by drafting error
– 191 certificates ok (irrespective of non-drafting error)
– 153 certificates with other non-drafting error issues
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Where we are now?
•
Versions of Ofgem’s RHI Emissions Certificates:
1. Consultation version – published July 2012, in annex B
2. Version 1.0 – published 3 September 2013
3. Version 2.1 – published 18th December 2013
4. Version 2.2 – published March 2014
•
The Ofgem template is not mandatory
•
But must contain all the information listed in the Ofgem template (taken
directly from Schedule A1 of the Regulations)
•
It must be issued by a testing laboratory and signed
•
Test lab must be accredited to ISO 17025 if the testing after 24th September
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Other issues with certificates
•
•
•
•
Type testing range:
– producing a separate certificate for each boiler tested in the range which
individually do not satisfy 2:1 ratio
– Including boilers above and below 500kW on one certificate and not clear
which standards tested to
Date of test – given as a month or a series of dates
Max moisture content – referring to EN303-5
Note: non-drafting error aspects of a certificate don’t affect the effective date - it
only delays them getting accredited
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Updated certificate
•
•
•
•
•
The updated certificate includes clarifications and advice as well as the December
changes
The advice has been added based on common errors we have been seeing since
September so mistakes will hopefully reduce over time
New certificate commissioned should be in template version 2.1 or 2.2
Certificates in template version 1.0 and without any others issues continue to be
valid for applications submitted subsequent to drafting error being resolved
It has been sent directly to testing laboratories and manufacturers as well as being
updated on our website
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Ofgem actions
•
•
•
•
•
We are engaging with test labs and manufacturers directly to obtain additional
information need to accept current certificates
We have dedicated topic specialists to ensure consistent and informed responses
Collating feedback on the certificate for future updates
Directly contacting test labs and manufacturer with updates regarding
requirements: max moisture content, drafting error
Manufacturers are encouraged to contact us if they have any queries before
commissioning certificates
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Resolution to common issues
1.
2.
Max moisture content
– DECC have confirmed that it is acceptable for maximum moisture content to
be based on ranges given in EN 303-5 (and by extension EN14961), if testing
carried out in accordance with EN 303-5.
Supporting documents
– Acceptable in some circumstances where it is required to clarify information
provide on the RHI Emissions Certificate.
– Must be issued by the same testing lab and must not contradict any of the
information provided on the RHI Emissions Certificate
– E.g. the original test report is provided to show testing was done on one
occasion.
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3. Type testing range
•
Must follow the ratio rules: ratio between smallest and largest plant must be no
more than 1:2 (or 500kW if smallest boiler is over 500kW), with at least one boiler
within that range tested
•
However if several tested boilers are included on one certificate, the type testing
range can exceed 1:2 as long as each tested boiler covers a 1:2 range, e.g.:
•
•
type-testing range contains boilers: A(20kW), B(30kW), C(50kW), D(60kW),
E(100kW), F(200kW) and G(400kW)
tested boilers:
• B (30kW) covers boilers A and B
• D (60kW) covers boilers C and D
• E (100kW) covers boiler E
• F (200kW) covers boilers F and G
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4.
Certificate with tested boilers above and below 500kW
• If one certificate covers boilers, some tested to different standards EN303-5 but
some not. If none fully complied with the standards EN14792 and EN13284, then
it is affected by the drafting error. The boilers tested to EN303-5 will meet the
requirements under the Amended Regs, but those not tested to EN303-5 will not.
However if everything else with the certificate is ok it will be valid for those boilers
that were tested to EN303-5.
5.
Capacity
• If the tested plant is not listed in the type-testing range, the certificate can apply
to any plant that is the same model, even if the installation capacity is different
• The capacity provided for the tested plant should be the peak heat output
capacity
• The capacity of any models in the type-testing range should be included
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Advice for completing certificates
•
•
•
•
Certificate reference number (question 1c) – unique reference number and date
of issue for the certificate itself, not the original test report it was based on. If a
certificate is amended and reissued, a new reference number should be used
Details of boiler tested – use the details as shown in manufacturer’s literature and
use maximum capacity
Date of test – provide the actual date of testing the emissions at nominal output.
If several boilers tested, please specify which date relates to which boiler.
If a boiler has not been tested but is included in the type testing range, it should
be included in question 2g on the certificate for the tested boiler(s). It should not
be issued on a separate certificate.
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Wood stores and moisture
The new risk
• New non-compliances may arise where fuel is wetter than allowed for in emissions
certificates
• In such cases we will have to stop payments
• Poorly designed outdoor stores may result in water condensing inside the store and
dripping onto the wood
• Wood stores can get so wet that grass grows on them – or they catch fire
Technology Strategy Board
Review of renewables in operation
Looked at over 50 buildings with renewables
Of which 23 were biomass systems
Early stage reviews
•
•
•
Many biomass systems working as specified - but
School 1 – biomass boiler hadn’t worked properly since commissioning
– School authorities concerned about risk of CO in wood store
– Maintenance costs and fuel costs discouraged use
School 2 – Significant periods of non-operation
– Auger/Screw feed size incorrect
– Unconfirmed reports of flue gases circulating in nearest classroom
Other school issues
•
•
School 3 – Boiler not used due to problems
– Original issue was sprinklers soaking fuel store
School 4 – Biomass boiler with supporting gas boilers
– Biomass rarely operational in first year
– Underlying cause, moisture problems caused by complex design of access
system to store which allowed water ingress
Biomass Sustainability
• DECC intend to introduce new sustainability criteria for existing and new
participants of the RHI in autumn 2014 to ensure installations using biomass fuels
meet the Government’s environmental objectives.
• All RHI participants using biomass feedstocks in their installation will need to
comply with the sustainability requirements from the date the criteria come into
force. For the non-domestic scheme the main method to meet the sustainability
criteria is:
• Sourcing woodfuel from the Biomass Suppliers’ List (BSL) [BSL is administered
by Germserve]
• We would encourage you to make your supplier aware that they should register
on the list as soon as possible, or register yourself if you are self-supplier
• This is based on information provided by the Department of Energy and Climate
Change – who have provided a factsheet with further information which is included
in your packs.
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