I thank the Minister for her introduction to the regulations before the Committee today. This instrument is simple but effective and its aims are largely technical. It modifies for a period of 12 months the application of two aspects of the combined heat and power quality assurance scheme in relation to the effects of the Covid-19 pandemic on the performance of CHP operators that resulted in shortfalls in their standards in the provision for the previous calendar year.
The Government have agreed to allow a temporary easement to the certification process necessary to enable CHP operators to continue to access multiple benefits,
such as carbon price support taxes and emissions performance standard limits. Indeed, 2020 was a very abnormal year as well as an inappropriate one on which to submit performance data. These regulations modify two instruments—the Renewables Obligation Order 2015 and the Emissions Performance Standard Regulations 2015—to refer to the technical Issue 8 of the CHP quality assurance standard. CHP operators can submit their 2019 operational data instead of the 2020 data for the 2021 certification. Issue 8 was published on 11 March 2021 to reflect this temporary easement for CHP plants impacted by measures implemented in response to the pandemic.
I am content to approve this order to allow a recovery period in which CHP operators can continue with data from the previous year’s performances. Do the Government believe they have judged the length of dispensation period correctly? What calculations have they undertaken to assess the slippage effect of the pandemic and whether a shorter period of time might have been sufficient for operators to get back on track?
I imagine that all the failing operators will have applied for this dispensation. Can the Minister tell the Committee how many operators the Government estimate may apply, and will the submission only of data from 2019 qualify them for certification? Will the operators need to demonstrate how Covid-19 impacted their business performance? Have the Government considered that there could be CHP plants that might have fallen short and yet not have been severely impacted by Covid-19? Would this matter, as it is the data that is not impacted and not the quality of standards? Perhaps the Minister might explain, as the measures implemented to combat Covid-19 may well have affected all performances, irrespective of district or operational abilities. However, that the data provided in 2019 would be sufficient to qualify for continuation of benefits would suggest that a large degree of compliance will not have changed, only the data achieved in 2019 for those shut or intermittently open during 2020.
I agree that it may not be necessary to implement a complicated bureaucratic quality assurance threshold for the various degrees of impact in 2020, and this SI seems straightforward in that respect. Can the Minister say whether any serious concerns were raised in the consultation?
I hope that as the economy recovers and the inoculation process continues to offer protections from the extremities of disease impact we will see a swift return to better operational performances. Do the Government consider that the audit of standards should become part of next year’s process of certification or do they consider that the return to data standards provided by the immediately preceding year will be sufficient? Naturally, I sincerely hope that there will be no need for further reconsiderations for next year if the UK should experience a return to lockdown measures.
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