PROPOSED CHANGES to the Renewable Heat Incentive scheme to remove 'drying' from the list of approved uses of that heat could have a 'profound' negative impact on rural businesses.

Responding to the consultation "The Non-Domestic Renewable Heat Incentive: Further Proposed Amendments", both the National Farmers Union Scotland and landowner body Scottish Land and Estates have warned Ofcom that its proposals to clamp down on misuse of the RHI scheme – in part prompted by Northern Ireland's 'cash for ash' scandal – were wrong to target legitimate drying operations.

The RHI was introduced to incentivise the installation of renewable heating systems, helping to bridge the gap between the cost of such systems and the fossil-fuelled conventional alternatives.

SLaE said that removing support for drying through the scheme – which would include wood fuel drying, crop drying, drying of material used for animal bedding, drying of animal feed and waste drying – would impact on businesses' willingness to make that investment.

Policy officer Gavin Mowat said: “The UK Government is responding to concerns about the misuse of the Renewable Heat Incentive and we appreciate the need for this to be examined. However, rural businesses in Scotland that are legitimately accessing the scheme to support the generation of heat from renewable sources should not be disadvantaged by the actions of a minority.

“The RHI scheme is designed specifically to offset the use of fossil fuels. The process of drying is a major consumer of fossil fuels in value adding and processing agricultural and forestry products, especially in Scotland with its relatively wet climate," said Mr Mowatt. "We are concerned that without an appropriate level of support, investment in renewable drying will stop and businesses will opt to remain using fossil fuels, thus undermining the drive towards lowering carbon emissions."

SRUC senior renewables consultant John Farquhar said that the consultation 'lumping in' crop drying with woodfuel drying was simply not logical – whether or not anyone would bother drying woodfuel or animal bedding without the RHI was open for debate, but crop drying was a practice that had always happened and always would.

"If we just take Scotland with an estimated three million tonnes of dried grain production a year, in an average year (not this year as drying use would have been far higher) one would expect most drying taking the grain from about 18% down to 13% final moisture for long term storage. This has always happened and always will, RHI or not.

"This represents removing 183,000 tonnes of water in Scotland’s cereal harvest alone, at an estimate this would use about 22million litres of kerosene or 220million kWh of energy with an associated 66,000 tonnes of carbon. This is a considerable legitimate use, and doesn’t include oilseed rape and other crops which are dried."

Mr Farquhar doubted that a blanket drying ban imposed on new RHI installations would do much to reduce wood-drying, as the woodfuel market was already saturated with existing suppliers who have more than enough drying capacity to meet their needs.

"The ones who would have been most likely to go into RHI and will be affected most by the ban, are grain drying systems – farms where the old dryer is coming to the end of its life and would need to spend the capital anyway."

NFUS agreed that on-farm grain dryers should remain part of the scheme, pointing out that, as farmers are paid on weight for their grain, there was little incentive for abuse as any over-drying would lead to lighter weights and less revenue for their crops.

Policy manager Gemma Cooper said that farmers only dried crops if necessary – but during this year’s harvest, with grain sometimes being cut at more than 30% moisture content, efficient drying through RHI-supported dryers was vital.

“Many farmers have invested heavily in drying systems based on the RHI, which the Government put in place to bridge the gap between costlier renewable heating systems, and conventional alternatives. Such investments have been made because grain drying was listed as an ‘eligible use’ for RHI, and would have been unlikely to have occurred without it," she stressed.

“RHI has allowed farmers to change to more eco-friendly drying systems, with huge savings in terms of gas or oil used and carbon dioxide emissions. Drying as an eligible heat use is something which the Government must retain."