With the closure of the Renewable Heat Incentive to new applicants, OFGEM and BSL now have more available time and are conducting more audits than ever before. Should they discover that a recipient lacks the necessary permits and permissions, they will promptly inform the local authorities that a government-funded installation is non-compliant.
The Renewable Heat Incentive (RHI) has closed its doors to new applicants. Nevertheless, this government-led initiative, aimed at promoting the adoption of renewables in industrial wood-fired boilers, remains a significant incentive. Accredited installations will continue to benefit from the scheme, receiving payments for the next two decades.
Or will they?
This scheme applied to non-domestic installations involving industrial wood-fired and biomass boilers. It did not cover industrial wood-fired or industrial biomass heaters, with direct warm air heaters being excluded.
Wood and wood-waste products from industrial wood-machining processes that are used in industrial wood-fired boilers are categorised as burning waste. This classification extends to burning natural timber if it occurs as a by-product of a manufacturing process. It is worth noting that in the initial stages of the scheme, wood waste from virgin timber was not officially recognised as waste until 2013.
The RHI scheme is overseen by two regulatory bodies: OFGEM and the Biomass Suppliers List (BSL). They are currently conducting audits to ensure that companies comply with local authority regulations. When it comes to the combustion of wood waste in industrial wood-fired or biomass boilers, three additional regulators are involved: Environmental Health, the Environment Agency (EA) and SEPA in Scotland.
Some of these regulations were introduced relatively recently, while others date back to the 1990 Environmental Protection Act. However, these regulations often go unnoticed and are not enforced by regulators due to time constraints.
With the closure of the Renewable Heat Incentive to new applicants, OFGEM and BSL now have more available time and are conducting more audits than ever before. Should they discover that a recipient lacks the necessary permits and permissions, they will promptly inform the local authorities that a government-funded installation is non-compliant. Payments are withheld until compliance is achieved or the installation can be removed from the scheme.
So, what is needed?
The most recent version of Guidance Note PGN6/02, which was revised in 2012 (updating the 2004 edition), pertains to the manufacturing of wood-based products. To operate legally, you must obtain this permit if your annual wood or wood-based product-processing exceeds 1,000m3.
It is important to note that in this context, “processing” includes purchasing. However, there is an exception for those exclusively involved in sawing wood, where the limit increases to 10,000m3 (typically applicable to sawmills).
This guidance note does not cover wood-combustion processes. However, if you do have a wood-combustion system, such as a boiler or heater, you can include it under this permit, depending on the size of your equipment.
The answer is all sizes. There is no cut-off point.
Plants incapable of burning more than 50kg of wood waste per hour need an exemption from the Environment Agency to burn waste as fuel. You can apply for this online and there is currently no charge.
If you burn over 50kg/hr but not more than 90kg/hr, you will need a Part B permit from Environmental Health. If you already hold this permit for your wood-machining process under PGN6/02, you can include the combustion equipment. However, if you don’t have a permit for wood-machining and your processing volume is below the 1,000m3 limit, you will need a Part B permit for a SWIP (Small Waste Incineration Plant). These permits typically cost £1,650 and come with an annual maintenance fee.
Under the MCPD (Medium Combustion Plant Directive), the next category encompasses boilers with capacities exceeding 90kg/hr but not more than 225kg/hr. Companies falling within this range will require a Part B permit, as detailed earlier, and are likely to surpass the 1,000m3 processing limit. If the boiler capacity exceeds 225kg/hr, you will need an EA permit for the industrial wood-fired boiler. Importantly, you will still need a separate permit for your wood-machining process.
To obtain an EA permit, you will need to request a quote from the EA. The cost of the permit varies based on the specific work and the location of your site, typically ranging from £3,000 to £16,000.
So, what else is required? All chimneys serving an “industrial furnace” need planning permission or written proof of permitted development. They will also require chimney height approval and a written chimney height determination, which must be submitted to Environmental Health. If your site is within two kilometres of any Sites of Special Scientific Interest (SSSI), you may be required to undergo comprehensive computer modelling.
At Ranheat Engineering, we offer free, confidential advice to new and existing customers regarding permit regulations. Chris Franklin, our managing director, has been dealing with the relevant legislation since the mid-1980s and has worked closely with the various authors of the guidance notes. He has also been a member of the board of directors of the WMSA (Woodworking Machinery Suppliers Association) since 2004.