Category Archives: Compliance

RHI – Further update

Letters have now been issued by DfE to all RHI beneficiaries. Ricardo have been appointed to carry out the inspections. The text of the letters is below:

“INSPECTION PROGRAMME FOR THE NON-DOMESTIC RENEWABLE HEAT INCENTIVE SCHEME”

I am writing to inform you that the Department for the Economy (DfE) has appointed Ricardo Energy & Environment (Ricardo) to undertake the inspection programme for the non-domestic renewable heat incentive (RHI) scheme. This page answers questions about the inspections: https://www.economy-ni.gov.uk/rhi-inspections-questions

The inspection programme will commence on 21 August 2017 and will consist of both announced and unannounced inspections. The Renewable Heat Incentive Scheme Regulations (Northern Ireland) 2012 permit the inspection of RHI installations and your co-operation with facilitating access to your site(s) during the inspection programme would be appreciated. If you are selected for an announced inspection you will receive notification from Ricardo. The inspection process will involve a technical check and business analysis of each installation. Where there are multiple installations on a site the business analysis will involve a holistic view of the site. The following will be assessed for each installation:

  • Compliance with the Scheme Regulations and supporting Scheme Guidance including the participant’s ongoing obligations and, in particular, assess:
    • if the heat is being used for an eligible purpose; and
    • whether there is any evidence of heat being wasted.
  • The business operation of each installation:
    • including, but not limited to, costs incurred and RHI income generated;
    • if the heat use is economically justifiable (based on the amount of heat used for the purpose undertaken); and
    • if the energy management practices in place conform to industry standards and best practice.

The inspector will also request invoices relating to the RHI installation, its ongoing maintenance and invoices for the fuel used in biomass installations. I wish to thank you for your cooperation with this inspection process and if you require any further information please contact the Department at RHIinspections@economy-ni.gov.uk

RHI Inspection Tender update

Further to our original briefing, the original tender issued by the Department for the 100% inspection of boilers was clear in its purpose but the Department did not award a contract as a result of that tender. A new tender is likely to be issued.

It seems very likely that the department will pursue suspected misuse, ineligibility or failure to observe energy efficiency best practice within the Non Domestic scheme including excessive heat consumption or inappropriately made application e.g. predominantly domestic schemes.

In the context of energy efficiency, compliance with best practice is a stipulated RHI requirement and that is fundamentally demonstrated by specific energy use e.g.  energy use in relation to floor space (kWh/m2) or a similar benchmark. It does not take a great deal of imagination to see that excessive consumption would merit a much higher priority inspection and scrutiny and, indeed, it would be then ultimately the participants responsibility to prove their compliance and continued eligibility to the Department.

Perhaps obviously, as well as having a justifiable energy consumption, the participant will need to have a ‘clean’ installation in terms of the Ofgem application and actual installation to prove their compliance.

There is therefore a valuable window of opportunity. We continue to offer our previously explained service

If you would to discuss your installation further please contact us using the following form:

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RHI Inspections

Are you in the RHI Non-domestic scheme?

Do you know that you are now going to be inspected this year (100% of installations are). If you fail your inspection your payments may be stopped or they may even ask you to repay some of your RHI income.

The inspections are very onerous and we can help you with a pre-inspection audit. This is very comprehensive and the outcomes are:

  1. You comply
  2. You fail and we tell you where and what you have to do to comply
  3. You fail and there are unfixable reasons why

As part of our audit we will provide you with a compliance report which will give you confidence that when the inspection comes, you will be in a good position.

If you are interested why not contact us using the form below

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MSCPD – Medium Scale Combustion Plant Directive

“To improve the quality of the air we breathe we need to tackle air pollution at source. With this directive we complete the regulatory framework for the emissions from the combustion sector. This is a key piece that was missing and that will help to significantly reduce the potential risks to human health and the environment”, said Latvian Minister Kaspars Gerhards, president of the Environment Council under Latvian presidency.

 

This is the basis of this directive which aims to ensure that combustion plants in the range 1MW to 50MW manage their emissions to improve air quality. There are an estimated 142,986 plants in the EU that will be covered by this directive so the impact on air quality will be very significant, particularly in areas where air quality is considered to be unacceptable and also where plants are obviously violating the guidelines.

What pollutants are considered:

Sulphur dioxide, nitrogen oxides and particulate matter. These are particular co-products of biomass combustion.

What will the process be?:

Step 1 : Registration – this process will be compulsory and gets your plant identified.

Step 2: Compliance – rendering the pollutant output of your to be lower than acceptable limits.

If successful:

Step 3: Certification

If unsuccessful

Step 4: Corrective action

If still failing:

Step 5 : Fines ?

Step 6: Shutdown?

What should you do?

Act now and ensure that you comply

We will help you audit your plant and advise you if you need to take corrective action.

Our extensive knowledge of all forms of combustion fuels and biomass in particular will allow us to help you find the most cost-effective way of ensuring that your plant will comply.

Undoubtedly there will be a rush to comply once the deadlines are live but why wait.

 

RELEVANT DOCUMENTS:

Directive   – This is the basic document setting out the principles
Annexes   – This explains data, such as emission limits etc