The Scottish Government has recently launched an important consultation on its Circular Economy and Waste…
Here at ADBA, strong relationships with government and regulators are crucial to supporting members and ensuring their interests are represented. This includes a quarterly meeting with Ofgem and last week ADBA met with the Regulator to discuss industry matters. During the meeting, Ofgem provided some important on the Green Gas Support Scheme (GGSS) and the Non-Domestic Renewable Heat Incentive (NDRHI).
GGSS Scheme – Updates
Current update on the GGSS application queue:
- 13 tariff guarantee applications have been made
- 9 provisional tariff guarantee notices given
- 1 provisional tariff guarantee notice rejected
- 8 tariff guarantees granted
- 2 tariff guarantees rejected
- 0 applications for registration in respect of additional biomethane
- 0 participants registered in respect of additional biomethane
- 0 additional capacity rejected
Overview of the metering arrangements for the GGSS
Ofgem stated that there is an issue with the data submitted by the GGSS participants, related to measuring heat for biogas production for biomethane. It is important that the data submitted are robust, verifiable, and not open to manipulation; hence the Ofgem recommends the participants follow the obligations of the scheme under regulation 9 of the GGSS Regulations 2021, with the data submission.
The emphasized guidelines are:
(10) A participant must provide measurements in such format as the Authority may request which satisfy the Authority of all of the following,
a). the gross calorific value and volume of biomethane injected,
b) the gross calorific value and volume of any propane contained in the biomethane,
c) the kWh of biomethane injected, together with supporting meter readings andcalculations,
d) the kWh of heat supplied to every anaerobic digester (other than heat contained in the feedstock to produce biogas by anaerobic digestion) which made the biogas used in anyquarter to produce biomethane for injection, and
e). any heat supplied to the biomethane production process.
The Ofgem’s expectations in this aspect are;
- Metering Arrangements must be set up in a way that sites can always provide Ofgem with the heat to the Anaerobic digesters with a final value in kWh.
- kWh value expected to be recorded as a cumulative value, or derived from a meter recording a cumulative value.
- Measurements are verifiable to measurement equipment (i.e. in that a photograph of physical meter can be provided as part of the evidence given in each quarter)
- Equipment not open to manipulation (e.g. to meters with anti-tamper proof measures, site measurement and control (SCADA) systems locked down by manufacturer)
- Measurements Reliable and continuously recording
FAQs on GGSS
Are there any KPIs implemented on GGSS applications?
- Currently, there is a low volume of stage 3 applications where only 1 application is working on submitting a stage-3 application. The KPIs would be similar to the NDRHI application where each application is assessed individually.
- The Ofgem expects to introduce KPIs for the GGSS in the second quarter of 2023 where more stage-3 applications are anticipated.
What is the timeframe for processing stage 3 GGSS applications?
- Ofgem is adopting the same approach to the NDRHI application assessment. Currently, there is no set application review timescale for stage 3 applications in GGSS. The timescale depends mainly on the quality of the application submitted and more specific information is needed to inform about the timeframe for a particular application.
- Review timescales are communicated via the Ofgem website.
What are the expectations Ofgem has for the sites?
- A key expectation when building the sites by the participants of the scheme is that the heat meters being installed to directly record heat in Kwh to the digesters only.
Can the participants share the pressuring equipment and/or the injection equipment?
- Pressuring and/or injection equipment cannot be shared.
Can participants use alternative metering arrangements?
- Ofgem are open to discussion with any applicant on reasonable alternative metering arrangements
When it comes to eligibility criteria, are there any options for using a private pipe?
- This comes down to the way the scheme is designed by BEIS (clarified in Regulation 2 definitions). GGSS applicants must enter into a network entry agreement which is why private pipelines aren’t eligible.
Can biomethane producers claim GGSS on biomethane produced remotely and injected via an injection point?
- Participants on the GGSS must specify an injection point for their application, and this injection point should be used to inject into the grid. This must be the injection point referred to in the network entry agreement as well.
- The ‘equipment used to produce biomethane’ includes pressurisation, propanation and odorant equipment, and the regulations are clear that this equipment must not have been used for registration on the NDRHI or GGSS, so cannot be shared with another producer registered with that equipment.
- The GGSS claims should be made by the producer of the biomethane, and the definition of biomethane is “biogas which is suitable for conveyance through pipes to premises per a licence under section 7 of the Gas Act 1986 (c. 44) (gas transporter licences) “.
- The registered producer also needs to be able to demonstrate compliance with the ongoing obligations and collect the necessary data required to claim payments. This will include feedstock information, heat deductions to biogas or biomethane production and propane and injection volumes.
Key takeaways for members:
- GGSS participants must follow the obligations for obligations of the scheme under regulation 9 of the GGSS Regulations 2021.
- The data submitted by the participants to the Ofgem needs to be robust, reliable, continuously recorded, in the right format, and not open to manipulations.
- The review timescale for GGSS applications depends on the quality of the application. Currently, there are no stage 3 applications are submitted, and updates on the timescale for stage 3 applications will be published on the Ofgem website in due course.
NDRHI – Updates
Ofgem stated that currently there are 9 biogas applications with an approved extension that have yet to submit their full application. Moreover, the NDRHI queues are all up to date, and as of yet, Ofgem has had no issues with the applications.
It must be noted that while the deadline for applications has been extended twice already, the current deadline is not likely to be amended in future. Any future applicants must note that this deadline is to be considered the final.
The deadline specified in the notice to commission for biomethane, commence injection and apply for full accreditation is 31 March 2023.
Key takeaways for members:
- NDRHI application deadline for biomethane, commence injection and apply for full accreditation is 31 March 2023. This deadline is to be considered final and is highly unlikely to be amended.
The next quarterly catchup with Ofgem will be held on 7th December 2022. We will provide any updates we receive from them in the meantime via our weekly newsletters.
If you have any questions or concerns regarding the GGSS and/or the NDRHI, please reach out to Wasundara Doradeniya via firstname.lastname@example.org