Don’t fall foul of an RHI audit – make sure you keep biomass fuel records

Sustainable Fuel Register (SFR) co-founders, Kevin Lindegaard of Crops for Energy and Jon Swain of FEC Energy, attended the inaugural meeting of the Renewable Heat Incentive (RHI) Industry Forum last week. This is a new initiative, coordinated by Ofgem, enabling industry bodies to provide feedback on procedures and documents associated with the delivery of the Domestic and Non-Domestic RHI schemes. This will help ensure that documents are designed with the needs of applicants and participants in mind.

The meeting included an update on compliance and enforcement as well as providing some interesting information on the auditing programme. So far, there have been around 500 audits of solid biomass systems. The number one issue identified by the auditors, where an RHI participant was failing to comply with the scheme rules, is the lack of fuel records. The Ofgem officials involved said that around 70% of all users audited were found wanting in this capacity.

Unfortunately, many RHI participants don’t realise that they have to fulfil ongoing obligations. But failure to have the right fuel records could lead to Ofgem withholding or reducing participants periodic support payments.

If you are worried that you’re not complying with the RHI rules, then your first port of call should be the Non-Domestic RHI Easy Guide to Compliance, which provides information on all the things you need to do during the 20 years of your non-domestic RHI agreement. You should also consult the Guide to keeping fuel records. Whilst this was produced in 2015 and needs an update to include SFR, it is, however, a useful document that provides examples of the type of fuel log books that would satisfy the auditors.

Information that participants need to retain includes:

• Volume or weight of biomass fuel used (and how you measured this)
• Type of biomass fuel used (e.g. sunflower husk pellets)
• Where biomass fuel is sourced from (e.g. purchased from a third party, self-supplied)
• Date the fuel was delivered
• Details of location where any harvesting took place (if self-supplied)
• Amount of fuel/feedstock purchased, including invoices (if purchased from a third party)
• Moisture content of your fuel (for applications made on or after 24 September 2013)
• SFR or Biomass Supplier List (BSL) authorisation number(s) of the fuel, if purchasing from the BSL or registered as a self-supplier (or producer-trader)

SFR registrants can request a copy of a spreadsheet that we have produced specifically for miscanthus self-supply and straw self-supply.

One real benefit of the SFR scheme, compared to BSL, is that users of SFR authorised fuel are required to create an account on the system. This means that all their SFR figures will be in one place online. Users of BSL registered fuel need to keep their invoices for the full 20 years of the scheme.