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ESA criticises 'complex and ambiguous' RHI draft guidance

The Environmental Services Association (ESA) has criticised draft guidance for the implementation of the Renewable Heat Incentive (RHI) for not sufficiently addressing the eligibility of commercial and industrial (C&I) waste, solid recovered fuel (SRF) and refuse-derived fuel (RDF).

In its response to an Ofgem consultation on draft RHI guidance, the ESA warns that the guidance contains no definition of SRF and lacks clarity over whether C&I waste streams are permissible under the RHI.

Director of policy Matthew Farrow said the guidance was “unnecessarily complex and ambiguous at the same time”.

He explained: “In principle, the RHI should help the waste management industry to deliver facilities producing renewable heat, but the details in the regulations and implementation guidance are simply not thought through.

“The result is confusion over whether extracting renewable heat from C&I waste is seen as desirable, and a set of overly rigid definitions of plant eligibility take no account of the fact that most EfW facilities plants take in a mix of waste streams.”

The ESA has criticised a portion of the guidance which states: “Installations using biomass contained in municipal waste can only use this municipal waste as their fuel source. If the installation is to be eligible for the RHI, non-municipal waste cannot be burned at the plant.”

The guidance adds that, under the Emissions Trading Act 2003, “municipal waste” carries the same meaning as “other waste that, because of its nature or composition, is similar to waste from households”.

However, the draft guidance also warns: “Where a participant wishes to use a mixture of household waste and other waste, Ofgem will need to be satisfied that all of this mixed waste can be regarded as municipal waste. This is because installations which use biomass contained in waste other than municipal waste are not eligible for support under the RHI.”

The consultation closed today (5 August).

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