Monksleigh’s analysis of the reporting by EFW plants in England1 show that there is no consistency in the approach to the way biogenic carbon emissions were measured by the 51 operational EFW plants in England.
The diagram below details the different methods used to calculate the percentage of biogenic carbon emitted by the individual EFWs with very different approaches and thus results.
Moreover, there was also limited consistency between the reporting by EFW plants operated by the same company – different plants often taking a different approach despite falling within the same company.
The challenges surrounding how any fossil carbon tax will be filtered down to customers in the implementation of UK ETS for EFW is already being widely considered by the Government and the sector, including how to get the consistency required for UK ETS when ‘waste feedstock’ or ‘fuel’ is so heterogeneous.
What seems to have been missed so far, though, is the potential for OFGEM’s REGOs (Renewable Energy Generation Order)2( (‘certification’ and payment approach for biogenic content3) to align with the UK ETS approach, with only 8% of those in the diagram above reporting that they use a REGO approach.
Clearly there is no room for the confusion that would arise if there were two different approaches to reporting and ‘certifying’ the biogenic/fossil carbon in the future (REGO and UK ETS).
In addition, the fuel measurement for REGOs varies between EFW plants as well (there are more than 8% of plants that claim REGO payments through OFGEM). A recent FOI to OFGEM by Monksleigh to understand the sampling approach was refused on the grounds that that they have no central or coordinated approach to reporting or understanding how each EFW goes about measuring REGOs, and for some reason see this important measurement of renewable power as in some way potentially ‘commercially sensitive’.
In summary, we now have increasing visibility of the variation in approach to the manner in which EFWs measure their carbon emissions, yet there is little consistency between sites and even within companies operating multiple sites. In addition, there is little alignment with the measurement of carbon under the REGO requirements and this will need to be addressed urgently to ensure credibility of the sector’s emissions and their payments claimed, as well as aligning with the future UK ETS.
For any help with understanding your waste analysis requirements and the implications for future UK ETS please contact us at info@monksleigh.com.
Post Script: ENDS Waste & Bioenergy reference this article in their article on UK ETS (dated 24th May 2024) and can be found via this link (although a subscription is required)Long-awaiting consultation into energy recovery’s inclusion in UK ETS released | ENDS Waste & Bioenergy (endswasteandbioenergy.com)
- 2023 Annual Performance Reports (APR) provided by operators to the Environment Agency ↩︎
- https://www.ofgem.gov.uk/environmental-and-social-schemes/renewable-energy-guarantees-origin-rego ↩︎
- https://www.ofgem.gov.uk/publications/renewable-energy-guarantees-origin-guidance-generators-agents-and-suppliers ↩︎
