Sustainability Criteria and the Carbon Calculator ADBA Crop Operators group, 20 March 2014

RO RHI FIT Sustainability criteria: key points GHG criteria April 2015 Land criteria April 2015 Default values used below 1MW RHI GHG criteria Oct 2014 Land criteria April 2015 Applies to all plant sizes FIT No current proposals Likely to change in future 2015 consultation England = 13% of households have separate food waste collections Wales = 82% of households Scotland = all LAs to introduce SS by 2015 Compare wales, scotland, england – how many source segregate? What does this mean for England

Sustainability criteria: GHG limits 60% saving on fossil criteria: EU heat or electricity carbon intensity RHI: 125.28kg CO2 eq per MWh RO: 285kg CO2 eq per MWh (to 2020) All consignments of feedstock must meet these limits Demonstrating compliance Operator can choose how to demonstrate compliance, either using calculator or own models Ofgem provides the ‘Solid and Gaseous Biomass Carbon Calculator’ as a tool for operators Includes default values but gives opportunity to edit these for individual sites If using own model this must follow the methodology government sets out and use the standard emission and conversion factors Audits required above 1MW (for the RO, tbc for RHI) England = 13% of households have separate food waste collections Wales = 82% of households Scotland = all LAs to introduce SS by 2015 Compare wales, scotland, england – how many source segregate? What does this mean for England

Sustainability criteria: land use Corresponds to the land criteria set out in the EU Renewable Energy Directive for transport biofuels and bioliquids Biomass cannot be sourced from land which at any time since January 2008: was primary forest, or a continually or lightly forested area was land designated for nature protection purposes (unless production of that biomaterial did not interfere with purposes for which this land was designated) was peatland (unless this did not involve the drainage of undrained soil) was wetland (unless that land is still a wetland). Where land use is changed in a permitted way, a carbon stock calculation resulting from the land-use change will need to be performed Operator will need to consider which category land has fallen in since 2008, and provide some form of evidence on this England = 13% of households have separate food waste collections Wales = 82% of households Scotland = all LAs to introduce SS by 2015 Compare wales, scotland, england – how many source segregate? What does this mean for England

Sustainability criteria: future RO Grandfathered for individual sites from point of accreditation RO shuts to new projects from 2017 RHI Not grandfathered for individual projects, as was originally intended DECC will review criteria every three years, so criteria could be changed in 2017 for implementation in 2018 DECC ‘expect changes to be incremental’ unless new EU legislation forces further changes we believe this will cause too much uncertainty for developers and have asked DECC to reconsider FIT Sustainability criteria likely to be considered again in 2015 review England = 13% of households have separate food waste collections Wales = 82% of households Scotland = all LAs to introduce SS by 2015 Compare wales, scotland, england – how many source segregate? What does this mean for England

Sustainability criteria: guidance Renewables Obligation Draft guidance published in early 2014 ADBA responded on several points Final guidance due to be published by April Renewable Heat Incentive Limited information in main Ofgem RHI guidance Would expect this to be developed as criteria come in Likely to follow similar structure as RO England = 13% of households have separate food waste collections Wales = 82% of households Scotland = all LAs to introduce SS by 2015 Compare wales, scotland, england – how many source segregate? What does this mean for England

Biomass Carbon Calculator Background Developed by E4tech on behalf of DECC to help demonstrate compliance with sustainability criteria Available for operators to download from the Ofgem website How it works Operator creates pathways for different feedstocks Default values available; operator can vary these but will need to provide evidence e.g. for lower fertiliser use or transport emissions Default values tend to be conservative, partly to encourage reporting of actual figures England = 13% of households have separate food waste collections Wales = 82% of households Scotland = all LAs to introduce SS by 2015 Compare wales, scotland, england – how many source segregate? What does this mean for England

Biomass Carbon Calculator England = 13% of households have separate food waste collections Wales = 82% of households Scotland = all LAs to introduce SS by 2015 Compare wales, scotland, england – how many source segregate? What does this mean for England https://www.ofgem.gov.uk/publications-and-updates/uk-solid-and-gaseous-biomass-carbon-calculator

Biomass Carbon Calculator Revision process First stage of revisions (for woody biomass) coming to end DECC allocating resources to update biogas and include RHI technologies such as biomethane Process underway to conclude over next few months ADBA working with DECC and E4Tech to resolve these issues Our key issues Clarifying the approach for apportioning emissions to different feedstocks within the ‘consignment’ Providing a more accurate figure for fugitive methane emissions, and clear guidance on how operators can vary this. A clear approach for apportioning emissions to digestate as a co-product Allowing a wider selection of potential feedstocks England = 13% of households have separate food waste collections Wales = 82% of households Scotland = all LAs to introduce SS by 2015 Compare wales, scotland, england – how many source segregate? What does this mean for England

Indirect Land Use Change Current approach Emissions from ILUC not generally considered at present Pressure from NGOs and others to include DECC work (BEaC Calculator) underway Future Expect it to be included at some point Could have a serious impact on reported GHG emissions for bioenergy Approach for AD very unclear – DECC have recognised issues are different to those for other forms of bioenergy following input/meetings 2017 UK Bioenergy Strategy review could consider this further England = 13% of households have separate food waste collections Wales = 82% of households Scotland = all LAs to introduce SS by 2015 Compare wales, scotland, england – how many source segregate? What does this mean for England