delete Greenhouse gas criteria
This Order amends the Feed-in Tariffs Order 2012, making technical corrections to interpretation provisions, updating tariff publication requirements for FIT year 8, inserting new article 35ZA on payment recovery notices, and inserting entirely new Part 8A establishing sustainability criteria, reporting obligations, and audit requirements for anaerobic digestion installations. It also adds Schedule 2A specifying greenhouse gas criteria for biogas production.
Feed-in Tariffs are a market distortion that forces energy companies to pay above-market rates for renewable generation, effectively a subsidy mechanism that picks winners and raises costs for consumers. This amendment compounds these harms by adding layers of compliance bureaucracy—quarterly declarations, annual declarations, mandatory audit reports for installations over 1MW, and detailed greenhouse gas calculations—that increase administrative burdens without improving the scheme's fundamental efficiency. The penalty provisions allowing reduction, withholding, or recoupment of payments represent punitive government intervention that deters investment. While this Order addresses technical aspects and sustainability criteria, the underlying FIT regime itself should be abolished rather than incrementally patched. The unseen costs include reduced investor confidence, higher energy prices passed to consumers, and deterred entry by smaller generators who cannot bear compliance costs.