Government response to informal stakeholder consultation
Updated 25 October 2022
There were a total of 52 responses to the notice published on 22 August 2022. These were provided by a range of organisations including industry, trade bodies, public bodies, businesses, and members of the public.
Most respondents expressed overall support for the proposal to temporarily suspend the fuel quality requirement for domestic and non-domestic Renewable Heat Incentive Scheme (RHI) participants using wood pellets.
Some respondents highlighted their concerns about air quality and particulate emissions resulting from using non-ENPlus pellets in biomass boilers. BEIS has worked with the Department for Environment, Food & Rural Affairs (Defra), the government department responsible for air quality, on formulating this proposal. While we recognise that this could have some short-term negative impact on fuel efficiency and air quality in some cases, on balance it is judged as acceptable so that homes heated by biomass do not experience significant price rises or a lack of fuel supply altogether during this period.
A few responses expressed the view that any temporary suspension should only apply to boilers of a certain size. Of these responses there were concerns over the impact that non-ENplus certified pellets could have on the performance of boilers, including on manufacturers’ warranties. We will work with Ofgem to provide guidance to participants to use wood pellets suitable to their boilers in accordance with their emission certificate.
Overall, most respondents believe that a 12-month suspension is adequate and will provide enough time for the market to adjust to the gap left by suspension of importation of Russian and Belarussian pellets. Some respondents agreed with the 12-month suspension but supported a longer suspension and some respondents disagreed with a 12-month suspension in favour of a longer suspension (for example 24 or 36 months) which would allow more time for the market to adjust.
Most respondents supported the proposal to give the Secretary of State the power to suspend the fuel quality requirement in the future if there is a risk of another pellet shortage. Respondents cited that having such power will allow the government to act more rapidly if there is a future shortage of wood pellets.
Overall conclusion
We are grateful for the valuable responses to this consultation. The government now plans to implement a 12-month suspension to the fuel quality requirement for RHI participants using wood pellets specified in Schedule 4A, paragraph 2. We are confident that a 12-month suspension strikes the right balance to make additional supplies of wood pellets available for this winter. In turn it should also serve to mitigate against potential price rises due to a lack of supply.
This temporary suspension will be enacted through secondary legislation and will apply to both the non-domestic and domestic RHI schemes. We will work with the Biomass Suppliers List (BSL) administrator to ensure that these pellets can be temporarily accepted on the List subject to compliance with other requirements. We will work with Ofgem to ensure that their compliance regime is adjusted to reflect the changes. We will work with Ofgem to update guidance for participants to be aware of the requirements stated in their emissions certificate when sourcing fuel.
Additionally, we are considering bringing forward secondary legislation to give the Secretary of State the power to temporarily suspend the requirement for domestic and non-domestic RHI participants to use ENplus certified pellets. This power could be used in situations of a shortage of wood pellets in the domestic market, with agreement across government. Our commitments to improve fuel efficiency and air quality remain; therefore, ahead of using such power, we will engage with the biomass industry and consider potential impacts on air quality and fuel efficiency.