Overview

An important feature of the Site is the existing ‘intermediate pressure’ gas grid pipeline that passes through it. This pipeline has sufficient capacity to accept all biomethane that the Proposed Development will produce for direct on-site injection to the national gas grid throughout the year. The proximity of this existing gas pipeline (with its spare capacity) was an important part of the locational justification for the choice of Site for the Proposed Development.

This feature was not however the initial focus of the planning application submission because, at that time (May 2023), there was no national scheme in place to support direct injection of biomethane into the grid.

The Government’s Non-Domestic Renewable Heat Incentive (NDRHI) had closed to new applicants (in March 2021), and its successor scheme – the Green Gas Support Scheme (GGSS) – had a closure date of November 2025, a deadline which was considered commercially unfeasible given that less than 30 months remained of that subsidy at the time of Application’s submission.

However, Government subsidies are subject to change, and it is important for commercial long term viability purposes to have operational flexibility to withstand such unpredictable external economic changes. The ability to benefit from Government subsidy support under one of these schemes is essential to the commercial viability of all AD plants, including the Proposed Development.

Transporting biomethane produced at the Proposed Development for injection at the nearby injection hub at Moraystown provides the ability to operate the project under a national scheme – as the Moraystown injection point is registered under the NDRHI scheme – and hence provided an immediate, commercially viable alternative to on-site grid injection. However, the ability to inject on Site was still a key consideration to ‘futureproof’ the project for its expected 25-year lifetime given the propensity for Government subsidy schemes to change.

The GGSS subsidy has now been extended. The GGSS Amendment Regulations 2024 extended the scheme closure date from 30 November 2025 to 31 March 2028 following the mid-scheme review of the GGSS. This means that the deadline is now more than 40 months away and this provides sufficient time to make the Proposed Development commercially viable as a GGSS project.

Additionally, business development activities undertaken during this period have identified several ‘off-grid’ distilleries located close to the Proposed Development that need to replace their existing dirty fossil fuel supplies (LPG and heavy fuel oil) with a clean, low carbon supply[1]. While the Scottish Government aims to reach Net Zero by 2045, the whisky industry seeks to get there five years earlier. To decarbonise by 2040, distilleries must harness zero-emission energy sources and one obvious source is biomethane gas, a carbon negative energy source fully supported by Government as an integral part of its strategy to reach Net Zero, provide security of energy supply and energy affordability.. 

The direct gas injection infrastructure now proposed enables the Proposed Development to have certainty of subsidy funding over its entire operational life, securing the delivery of urgently needed green gas to tackle climate change, contribute to a decarbonised and secure energy system and improving the viability of farming and prospering the rural economy.

The opportunity to undertake direct on-site injection into the gas grid also means the requirement to export the gas from Site by HGVs is potentially removed. Whilst the impacts of biomethane transport movements on the surrounding road network are minimal (at just 2 to 3 tankers over a 24-hour period), any reduction in traffic movements represents a betterment in local impact terms.