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CONSULTATION – BIODIESEL, GLYCEROL AND THE RENEWABLES OBLIGATION – Ref:
129/08
JOINT RESPONSE ON BEHALF OF GREEN2GO LIMITED AND CONVERT2GREEN
LIMITED
Respondents:
Green2Go Limited
Building 1000
Kings Reach
Yew Street
Stockport
SK4 2HG
Convert2Green Limited
Unit 1B
Brooks Lane
Middlewich
Cheshire
CW10 0JG
Introduction
Green2Go was established in 2007 to provide renewable and sustainable heat and power
solutions to its public sector and private sector partners.
Green2Go is a subsidiary of Equity Solutions & Partners Limited, a well established investment
organisation which invests in Public Private Partnerships. The Equity Solutions Group have
invested, procured or acted as principal leader on over £4bn of infrastructure transactions.
Green2Go are actively encouraging and implementing low carbon alternative fuel options and
associated infrastructure solutions across the property portfolios of Equity Solutions and other
partners‟.
Green2Go are working with partners including Convert2Green, who manufacturer high quality
biofuels which are used in the distribution and power generation industries.
Convert2Green focus on developing sustainable energy solutions for their clients, investing
heavily in the research and development of new products and the installation of quality
processes which provide high levels of fuel consistency.
Convert2Green has agronomy and chemical engineering partnerships working on the
development of the next generation of biofuels.
Green2Go and Convert2Green have jointly prepared and agreed this response to the
Consultation.
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Response
Chapter 1
We agree with sections 1.1 to 1.7 of the Technical Background Chapter Summary provided.
We would point out, however, that based on our Gas Chromatography data, the major
component fatty acid composition of our product is dependent on the oil source as is
approximately as follows.
Fatty Acid
Palmitic acid
Oleic acid
Linoleic acid
% composition by mass
5-15%
35-48%
27-45%
Description
C16:1
C18:1
C18:2
By calculation the average molecular weight, in these majority components, based on their
relative compositions, is approximated as 275.5 mass units assuming an average composition.
Using the molecular weight contribution from a fossil derived methyl group and an oxygen atom
the product contains 88.8% biomass: 11.2% fossil derived components by weight.
The reaction scheme, shown in section 1.5 of the chapter summary, depicts protons from fossil
derived methanol forming part of the final structure of the Glycerol molecule.
We cannot agree with this since the mechanism shown below, as reaction 1.5, clearly shows
the di-glyceride intermediate being protonated by water. Water is present in our reaction mixture
at a level of 0.2 – 0.4% by weight and occurs naturally.
Therefore it is impossible to say whether protonation occurs from naturally present water or from
water derived from methanol / hydroxide mixing.
Without further investigation, in the form of isotopic labelling and mass spectrometry studies, the
reaction scheme proposed in section 1.5 of the Technical Background cannot be substantiated.
It may serve as a general scheme of the reaction, for illustration, but in terms of the actual
reactions occurring, these are subtly different.
We can however be certain that the fossil fuel component of the FAME will be no larger than
12% by mass on average, and in the Glycerol no larger than 3%, by mass, although the actual
average will lie at much lower levels.
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Chapters 2 and 3
In respect of biodiesel, produced using methanol derived from natural gas, it is our view that the
approach to eligibility ought to differentiate between fuel produced using virgin methanol and
fuel produced using only reclaimed waste methanol.
We see the use of alternatives to methanol (i.e. biomass derived alcohols) as a key element of
our plans. However, we have previously made extensive efforts to address the issues that
natural gas derived methanol presents. Our approach was to source recycled methanol. It was,
and remains, our view that this method presents a sustainable alternative to the use of virgin
methanol.
Methanol is obviously used for numerous purposes, in industry, from plastics to explosives. It is
a toxic and volatile chemical, which must be handled and disposed of carefully. We therefore
believe that credit ought to be given to biodiesel producers who have taken steps to source and
reuse waste methanol, which might otherwise simply be disposed of.
The purpose of the Renewables Obligation is to incentivise renewable generation. We would
suggest that it is not in the spirit of the Renewables Obligation to exclude fuel in respect of
which the methanol, which is involved in its production, effectively amounts to waste that is
being reused. We would suggest that this process is, in itself, in the spirit of sustainability.
Whilst we understand your position in respect of the difference between contaminants, and
substances that alter the structure of the fuel in question, we believe that your approach is
inconsistent. Some generators are able to claim ROCs on a proportional basis and some are
not, based on what, we would suggest, is an arbitrary issue relating to the way in which
methanol affects the structure of the biodiesel.
We also believe that there are inconsistencies between the approach to transport as compared
with the approach to energy generation. Current environmental policy aspires to reduce UK
emissions of all greenhouse gases, irrespective of whether these gases are produced from
transport or energy.
With road transport, the RTFO policy has clear targets for fuel suppliers and generally succeeds
in providing sufficient incentives, on renewable fuels, to encourage suppliers to meet these
targets. The combination of financial incentives and tax penalties has resulted in a UK industry
that manufactures renewable fuels to meet the demand, and in so doing has created jobs,
income and revenue.
Energy production in the UK has been set higher long term targets, for renewable sources, than
road transport, and yet the legislation, or at least the interpretation of it, prohibits the use of
currently available renewable fuels and thereby discourages potential energy providers from
helping to reduce greenhouse gas emissions. If the spirit of the legislation was interpreted to
include biodiesel, glycerol and other currently available fuels, then these targets could be met
more readily.
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We are of the view that there ought to be a substantial rethink in the way in which biodiesel,
produced using methanol, is categorised. We are aware that your key consideration, on this
issue, is the way in which the constituent parts of the end product have reacted with each other.
However, as stated above, in terms of mass, the fossil fuel element of the FAME is
comparatively small. In respect of fuels produced in this way, from Used Cooking Oil, the vast
majority of that fuel is from a recycled waste stream. It is our view that, in order to achieve the
objective of the Renewables Obligation and to incentivise the reduction of greenhouse gases,
ROC‟s ought to be available for a FAME biodiesel, on a proportional basis, particularly where
that fuel has been produced using only recycled methanol.
Further, we believe that there are issues in respect of the way in which your approach to
biodiesel amounts to an undue restriction on the development and potential of Combined Heat
and Power (CHP) applications. We would contend that CHP applications are particularly
sustainable and efficient when compared with electricity, transport fuels or heat alone.
We would refer to a recent report from The Royal Society („Sustainable Biofuels: Prospects and
Challenges‟ – January 2008) in which it is stated, “Although on a greenhouse gas reduction
basis the most immediately effective use of plant material, in terms of conversion efficiency is to
generate heat, this is not always true when comparing combustion for electricity with conversion
to biofuels. There are real opportunities to develop biofuels that can deliver substantial
greenhouse gas savings.”
We contend that fuels produced from Used Cooking Oil, when used in combination with good
quality CHP systems, present an excellent opportunity to help achieve the objectives of the
Renewables Obligaiton and to reduce carbon emissions. However, this opportunity, far from
being incentivised, will be constrained by your approach to such biodiesel.
Chapter 4
We would firstly refer to our comments, on the composition of Glycerol, as set out in our
response to Chapter 1 above. Our position is that, on present information, it is impossible to
accurately assess the extent to which methanol contributes to the final structure of the glycerol
molecule but that further studies ought to assist on this issue.
As to the proposed interpretations, we believe that the second interpretation, namely „Partial
Exclusion‟ ought to be adopted. As the glycerol has levels that are definitely below 3% and
possibly below 2% we strongly believe that it should be classed as a renewable fuel.
As to your assessment of the benefits and consequences, of each interpretation, we appreciate
the relevance of factors such as establishing a clear standpoint, avoiding delays and reducing
administrative costs. However, we are of the view that the overriding factor ought to be the need
to incentivise renewable generation. On this basis, we would suggest that generators, who go to
efforts to utilise the co-product of their biodiesel production process, ought to be rewarded for
this.
You refer to the costs that would be involved and that the onus would be on the generator to
show what percentage of the glycerol does not contain hydrogen atoms from methane.
However, it would be a matter for an individual generator to decide whether it is worth their while
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to devote the time, and incur the upfront costs, that would be necessary to establish the relevant
percentage.
You also refer to the possibility that an accurate and reliable method, to ascertain the
renewability of the glycerol, might not be agreed. We would suggest that this could be
addressed on a simple percentage basis and that the key issue would be the ability, of the
relevant generator, to establish the make-up of their glycerol.
Further, whilst we appreciate that your key concern is the extent to which methanol contributes
to the structure of the glycerol molecule, we would also point out that the fossil fuel component
of the glycerol, when measured by mass, is at a low level (less than 3% - see above).
We would also comment on the reference to glycerol as a waste product. Two feedstocks are
involved, namely oil and methanol/ethanol, to make two products, namely biodiesel and
glycerol. Each of these products has a market price and a demand, in its own right. We
therefore strongly believe that glycerol is a product not a waste and should be classed as such.
Further, we would suggest that, the fact that glycerol currently has a lower financial worth than
the biodiesel does not justify the assertion that it is a waste product. We contend that other
factors ought to be taken into account in deciding whether a particular fuel should be
categorised as waste, such as simple demand for that fuel and the objectives of producers. For
example, as fuel manufacturers develop new fuels and as the market develops, the market price
for glycerol may well increase and, although unlikely, may exceed the value of the biodiesel. We
believe that a parallel can be drawn with fossil diesel, which, whilst being a by-product of
petroleum production, would not be considered as waste.
We would also like to comment on the issue of advanced conversion technology. The indication
is that fuel derived from such technology is acceptable. However, we would question whether,
for example, a wastewater operator could be sure that their waste is not fossil based. Such
plants are likely to take waste from various industries and we would question whether there is
therefore inconsistency in this regard.
Conclusion
We are grateful, to Ofgem, for the opportunity put forward our views and we hope that the
responses set out above are of assistance. Both Green2Go and Convert2Green would also
welcome the opportunity to answer any queries that arise or indeed to meet with Ofgem, to
contribute further to this process.
13.10.08