The Combined Heat and Power Association (CHPA) is the leading advocate of an integrated approach to delivering energy services using combined heat and power and district heating. The CHPA welcomes the consultation, Biomass Electricity & Combined Heat & Power plants – ensuring sustainability and affordability, and the opportunity to provide a response to Part B: Value for money & Affordability, specifically the proposal to create a cap on the number of ROCs which suppliers can access for new dedicated biomass.
The CHPA supports Government’s efforts to ensure cost control and to drive the most optimal use of biomass to meet emissions and renewables targets. The exemption of dedicated biomass CHP from the dedicated biomass limit will help achieve these two goals.
Care, however, needs to be taken with CHP treatment to avoid unintended consequences. There is a risk that an operator who loses their heat customer and becomes a dedicated biomass power-only power station would fall under the biomass cap after it has been reached, causing the operator to lose both the CHP uplift and any value from the 1.5 ROCs for dedicated biomass. This risk that the entire RO, not just the CHP uplift, could be lost to the plant will reduce the value of the RO in incentivising biomass CHP when compared to dedicated biomass heat boilers under the RHI. The risk is that the policy will cause developers to invest in biomass heat only boilers rather than renewable CHP.