DESNZ launched the Mid-Scheme Review of the Green Gas Support Scheme (GGSS) on 23 March 2023. The consultation ran for eight weeks, to which ADBA responded officially on 18th May. The Review called for stakeholder views on a number of topics, including:
- A proposed extension to the scheme to March 2026
- Proposals for the maintenance of the current tariff guarantee deadlines
- Proposals to maintain the current commissioning deadline
- Proposals to retain the current waste feedstock threshold, which is currently set at 50%
- The continuation of current requirements for digestate management
- Evidence on methane leakages and measures to mitigate leakage from GGSS plants
- Eligibility criteria for conversions of CHPs to biomethane under the scheme and a call for more detailed information on conversion and decommissioning costs
- Views for a future biomethane policy framework
ADBA coordinated an industry-wide outreach to gather evidence to support the response to the Review, including a roundtable discussion on CHP conversions with industry leaders and DESNZ officials in May 2023. In ADBA’s response, we emphasised the challenges faced by the industry due to the lack of feedstock availability caused by the delays to the announcement of Defra’s consistency in household and business recycling consultation.
ADBA’s recommendations and responses to the proposals put forward through the mid-scheme review are;
- Extension of the scheme closure date: ADBA recommended the government to extend the scheme deadline by additional 2-3 years to give sufficient time for those looking to build time to secure sites, planning, permitting, feedstocks and build plants.
- Maintenance of the current tariff guarantee and commissioning deadlines: Considering the limited uptake of budget and the supply-chain issues faced by the industry, ADBA recommended a flexible approach to the tariff guarantee and commissioning window
- Retain the current waste feedstock threshold at 50%: Given that the anticipated availability of food waste has not been realised, ADBA agreed with this proposal to maintain the condition that 50% of biomethane production should come from a waste feedstock.
- The continuation of current requirements for digestate management: While ADBA agreed with the proposal to enforce requirements under the Environmental Permitting Regulations to cover digestate stores, we emphasised that by enforcing the requirements of the Code of Good Agricultural Practice for reducing ammonia emissions, DESNZ may be inadvertently guiding operators away from other ammonia mitigation techniques.
- Evidence on methane leakages and measures to mitigate leakage from GGSS plants: ADBA fully supported the approach of DESNZ in addressing methane leakage.
- Eligibility criteria for conversions of CHPs to biomethane under the scheme: ADBA provided a mixed response to this proposal as a significant portion of the ADBA members agreed with the DESNZ approach while others didn’t. We emphasised in the response that, in the absence of support for CHP conversions, DESNZ must act now to address the end-of-subsidy concerns that many in the industry will face soon.
- Heat pump exemptions for heat deduction calculations: ADBA agreed with the DESNZ proposal on heat pump exemption.
ADBA policy team is currently working on its response to the GGSS Annual Tariff Review. If you have feedback on that, please email firstname.lastname@example.org by 5th June 2023.