Dear CRU Team,

Thank you for the opportunity to provide feedback to this important consultation. While IrBEA is not directly involved in the certification process for HECHP our members are. Our members of relevance to this consultation are biogas producer who operate CHP units and are in receipt of REFIT support. We have received feedback from our members in compiling our response. Our specific and high-level feedback to the consultation areas and questions are as follows:

3.1 Meter calibration requirements (Q1 and Q2)

IrBEA members have no objection to maintaining and submit a meter recalibration schedule. No improvements in the schedule are necessary.

Meter calibrations must be updated annually this requires the meter to be removed from site, and what happens while it is being calibrated – which might take a few weeks? It is sometimes easier to replace the meter with a new one but this puts a significant financial burden on biogas plant operator's. Could this period be extended to 3 years?

If electricity readings are taken from the grid operator directly, can it be assumed that the Eirgrid meters are accurate. How would you get a calibration cert for this in the first place?

3.2 Clarity on the treatment of losses from pipework (Q3)

Yes, we agree once the methodology is not complicated and overly burdensome to implement.

3.3 Leniency period for economic justification compliance (Q4 -Q6)

Yes, we agree to the one year leniency period however the once in 10 year period should be reduced to once in 5 years as market conditions can change. There is a query regarding how a change in heat use is treated in the context of the leniency period and this should be clarified.

3.4 Revisiting the HECHP submission process (Q7 and Q8)

Yes, we agree once the streamlined process see a reduction in application turnaround time and the issuing of HECHP certificates by CRU.

3.5 Simplification of Requirements for small fossil fuel submissions (Q10 - Q14)

Turnaround time of applications needs to be a continued focus.

Any simplification process should be applied to all biogas project under 1MW and particularly if the heat is used within the Anaerobic Digestion process itself. These facilities should be considered low risk

Biogas is disadvantaged by being treated on an equal basis to fossil fuels. As a renewable fuel it should be treated favourably over fossil fuels. The simplification of complex reporting and compliance requirements for biogas CHP should be a priority for the CRU allowing the biogas plant to focus on producing renewable gas and optimising their output. The benefits of the biogas sector span the circular economy, decarbonisation, valorisation of waste, displacement of fossil fuels, reduced methane emissions and other areas to name but a few.

No risk is foreseen from a biogas perspective of a self-declaration process.

3.6 Consistent operating period and deadlines for submission of HECHP data (Q15 and Q16)

A fixed January to December assessment period seems like a common-sense, standardised and transparent approach. Its effectiveness would depend on the ability of the CRU to process and issue HECHP certificates in a timely manner

3.7 Removal of planned plant certificates (Q17)

Yes we agree.

3.8 Publication of certificate holders (Q18)

Publication of a list only of certificate holders is not an issue however members have concerns around the privacy of the publication of energy usage data or specific operational information which would be plant specific and this being made available to the public and it could be used by competitors.

In addition, consideration should be given to noting the period in which the latest HECHP certificate was issued on any register. Giving the timeline from application to certificate issuing the perception maybe given the plants are not currently HECHP certified.

3.9 Request for feedback (Q19 - Q21)

We would like to receive feedback from CRU on our submission and a meeting to discuss the specific items.

Thank you for the opportunity to provide a response to this consultation. We are available to provide any further information that is required on behalf of members or answer any specific queries arising from our submission

Kind regards

Seán Finan B.E C.Eng MIEI

IrBEA CEO

0874146480

seanfinan@irbea.org

CRU Certification Process for High Efficiency Combined Heat and Power - Submissions

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