Defra’s Clean Air Strategy, published in May 2018, proposed that further support under the Renewable Heat Incentive (RHI) should not be available for biomass installations in urban areas with access to the gas grid. This consultation set out details of the proposed restrictions.
Objectives of the consultation
The Government proposed that biomass combustion installations should no longer be eligible for RHI support if they are located in urban areas that are on the gas grid. The proposed restriction would apply to new domestic and non-domestic biomass installations of all sizes, and also to biomass combined heat and power (CHP) installations. The Government proposed that this restriction would not include biogas, which does not create the same level of particulate and other pollutant emissions as biomass combustion.
For this policy proposal the Government used a common threshold of settlements of 10,000 or more to define urban areas.
Larger biomass plants are subject to planning controls and much tighter emission controls than smaller plants. However, even with these controls in place, they will still emit pollutants to air. This consultation therefore asked whether such plants should or should not be included in any restriction on RHI biomass.
The proposed restriction would only apply to new applications, however, there is an evidence that some existing RHI biomass installations emit pollutants to air at far higher levels than those specified by the applicable emission standards. One reason for this is the use of inappropriate fuels such as wood that is wet or contaminated. Another is equipment that is not maintained properly, resulting in its environmental performance reducing over time. This consultation, therefore, sought views on whether mandatory maintenance checks for existing and new installations should be introduced into the RHI.
This consultation was related to RHI schemes operating in England, Scotland and Wales. It did not relate to the separate RHI scheme for Northern Ireland.
The consultation closed on 27 November 2018.
To download the consultation document, please follow the link below.
CIBSE agrees with the proposal to remove RHI support for biomass in urban areas on the gas grid. The Institution noted that biomass installations have a negative impact on air quality both directly due to the particulate emissions from the biomass burners, and indirectly due to the emissions associated with fuel delivery. As the objective of this proposal is to avoid worsening air quality in areas where it is already unsatisfactory, consideration should also be given to excluding the Air Quality Management Areas from the RHI as well.
CIBSE strongly believes that existing biomass boilers installed under the RHI should be required to have regular maintenance checks. This would have benefits not only in terms of air quality, but also efficient operation and safety.
The Institution also suggested considering other options to improve air quality, including:
- Grading the RHI depending on the type of biomass fuel.
- Introducing quality (including moisture content) requirements within the Biomass Suppliers List (BSL).
- Carrying out emissions tests on smaller scale installations, not only large installations
To read the full CIBSE response, please follow the link below.