Select Committee on Environment, Food and Rural Affairs Written Evidence


Memorandum submitted by The Natural Gas Vehicle Association (NGVA) (Bio 16)

EXECUTIVE SUMMARY

  1.  The definitions provided by EFRA Select Committee are misleading and very limiting, and this response has been written using the meanings of the words such that:

    Bioenergy is the use of biofuel which was created using biomass as a resource

    Biomass is the resource used to create biofuel to make bioenergy

  2.  It is the considered belief of the Natural Gas Vehicle Association (NGVA) that bio-methane is the most appropriate biofuel, and that the route to increasing the use of this cleanest and most environmentally friendly renewable fuel is to extend the use of natural gas as a transport fuel in addition to its present use as a fuel for creating heat and electricity.

  3.  Most cities around the world accept that natural gas is the cleanest of all the fossil fuels. Bio-methane created from organic waste or by-products offers the same clean emissions but also offers huge carbon savings over all other fuels, renewable or fossil, bio or other, as a result of the avoidance of the methane emissions that would otherwise occur from the waste if it were not treated. As a greenhouse gas, methane when it is released to the atmosphere is 21 times worse than carbon dioxide, so the avoidance of this release should be the first priority of all those interested in protecting the environment. The energy used to create bio-methane is far less than that used to create any other biofuel, and because only low level energy is needed much of this can be from the sun or the wind.

  4.  Advantages of bio-methane over other biofuels whether liquid or gas or electric:

        Makes a positive contribution to the environment;

        Less energy used to create the fuel;

        Lower emissions created during the process;

        Lower emissions when used as a fuel;

        No particulates during creation or use.

  5.  Bio-methane or Renewable Natural Gas is the ONLY biofuel which offers all of these advantages.

  6.  This public consultation document, unless seriously challenged in its entire rationale as written, will lead the British government down a route which will damage our industry, the environment and the nation's health.

DEFINITIONS

  7.  The definitions used in the EFRA Committee Questionnaire are very misleading and unclear.

  8.  The first matter to be resolved is the definition of energy. There has been much misunderstanding over the confusion of the words energy and electricity. Energy usually needs a fuel to store it, so that it can be released in a useful form. Electricity only becomes energy when it is being used (or wasted), all fuels, including electricity, are created from a variety of resources. In some cases, fuels are created from processing other fuels. Electricity generally falls into this group. Some chains are very much more complicated, such as the resource biomass being used to create gas which is used to create electricity which is used to power electric vehicles.

  In this context there are three basic sorts of energy:

        Heat

        Light

        Movement

  9.   Resources can either be used to create energy directly or to make fuel which can be stored to make energy later.

  Resources from which to create fuel or energy include:

        coal

        crude oil

        natural gas

        wind

        uranium

        sun

        wave

        tide

        geothermal

        biomass:

sugar beet

wheat

wheat straw

sugar cane

rapeseed

sunflowers

grass

miscanthus

short rotational coppice (willow)

forest residues

woody waste

kitchen waste

animal waste

food processing waste

waste from bioethanol production

Etc

  10.  There are many processes for converting a resource to energy and most go through a fuel stage which allows the energy to be stored before being available to be released, although there are some examples where the basic resource converts directly to energy. For example no fuel is needed in a traditional windmill, which converts the wind resource directly into movement of milling wheels. Another example is where anything is burnt and heat is the required result.

  11.  In most cases the resources are converted into fuels:

        Petrol

        Diesel

        LPG

        Enriched uranium

        Bio-diesels including FAME (Fatty Acid Methyl Esters)

        Synthetic diesel

        Compressed natural gas

        Bio-methane also known as renewable natural gas or biogas

        DME (dimethyl ether)

        Alcohols including

Ethanol

Bioethanol including MT/ETBE

Methanol, also known as wood alcohol

        Hydrogen

        Bio hydrogen

        Electricity:

From fossil fuels

From bio-fuels

From other renewable sources

  12.  Most of these fuels can be created from a variety of resources. The most environmentally friendly fuels are those using biomass as their resource, and there are various processes to create biofuels. The resulting energy is known as bioenergy.

      Thus biomass—————>  biofuel—————>  bioenergy.

  13.  The most common processes which are used to convert biomass to biofuel include:
pyrolysisproduces heat and liquid bio-oil fuel
gasificationproduces heat and syngas fuel
anaerobic digestionproduces bio-methane fuel
transesterificationproduces liquid biodiesel fuel
fermentation and distillationproduces liquid alcohol fuel
combustionproduces high-grade heat which can be used to raise steam, used for making electricity
CHPproduces low-grade heat and bio-electricity


  14.  Apart from the obvious fuels made from the biomass, other useful products are often created during the process.

USES FOR BIOFUELS

  15.  Just as fossil fuels can be used for a wide variety of applications, the same is true with biofuels, with a variety of different chains. Each biofuel can be used directly for some applications, but need conversion to electricity before it can be used for other applications. The most versatile process for converting biomass to a biofuel is anaerobic digestion as it produces bio-methane which is equally suitable as a vehicle fuel, a source of heating, or to create electricity.

  16.  From the above it can be seen that the definitions suggested by the EFRA Committee for biomass and biofuels are somewhat misleading.

  17.   Biomass should be defined as all forms of biological matter. This can be found occurring naturally or as specially grown as crops, but are found in greatest quantities in the form of waste. Less than 50% of any food crop grown for human consumption is actually eaten (sprouts are a good example), and of this edible portion much is wasted (out of date or spoiled food, etc). The human body is not very efficient and much of the food which is actually eaten also ends up as waste, so the overall figure that 85% of any crop grown as food is "wasted" and is actually available as a source of biomass.

  18.  The current DEFRA definition of biomass refers only to "plant or animal matter used as a source of renewable heat or electricity." The words "source of renewable heat or electricity" should be replaced with the words "source of renewable energy". Energy cannot be restricted to heat and electricity, particularly when electricity is more strictly a fuel than an energy, but should encompass all means of creating heat, light, and movement. The definition "plant or animal matter used as a source of renewable heat or electricity" refers to one process only, combined heat and power. Presumably the EFRA Committee enquiry intends to be wider than just this one process.

  19.   Biofuels should be defined as all forms of fuel, whether gas, liquid or solid which are produced from biomass.

  20.  The current definition of biofuel refers to "petrol or diesel additives or substitutes produced from crops and other organic material". The phrase is extremely misleading and should be replaced with "all forms of energy produced from biological matter." As explained above biofuels are any sort of fuel created from biomass. The EFRA Committee is probably here referring only to biodiesel and bioethanol. Again, presumably the enquiry intends to be wider than just these two fuels. It should be pointed out that when Mr Diesel invented the diesel engine it ran on 100% bio-diesel and frankly the EFRA Committee definition as "additives" is extremely worrying. That the worst two performing fuels have been singled out for the definition is even more worrying and the NGVA require a full explanation as to why this definition was chosen and by whom.

  21.  It is not for the government to decide whether a gas, a liquid or a solid fuel should be used, which process should be used, or which biomass resources should be used. All uses should be encouraged. Once each industry is well established, with all the projected improvements in place, and performance figures are available, it will be possible to compare the energy balances and the financial cost.

  22.  The questions have therefore been re-worded more appropriately.

    (Q1)    (a) What is the real scope for biomass and biofuels bioenergy to contribute to tackling climate change?

  23.  The scope is huge, but has never been properly quantified by a thorough and detailed academic study. If organic waste is used as the biomass resource then the contribution to tackling climate change comes from two sources, the saving of methane emissions that would otherwise be released into the atmosphere, and the use of the resulting bioenergy to replace what would otherwise be fossil fuel energy.

  24.  What is required is a study similar to the EU Well to Wheels Study but quantifying all forms of biomass available. The saving from using cattle slurry and considering just the saving of methane emissions from this one biomass resource resulting from its use to replace fossil fuel, would amount to 14% of the UK's national emissions[34]. Actually, cattle slurry has one of the lowest gas yields of all organic wastes, so when other wastes are considered the figure will be very much higher. For example compared with the gas yield from cattle slurry, the yield from waste fat is 38 times higher and from pastry making is 25 times higher. It will be necessary to obtain figures giving the total quantity and type of the organic waste, residues and by-products emanating from all sources, industry, commerce, domestic, agriculture, horticulture, etc. At present these figures are not readily available and this really useful data would be available if DEFRA were to commission such a study.

    (b)    What proportion of the UK's energy heat, electricity and transport fuel needs could they provide?

  25.  Bioenergy would probably provide the UK with 50% of its heat, electricity and transport fuel if the necessary investment was available, but there are so many conflicting figures that it is essential to carry out a properly funded study of the total organic waste available as a resource. In addition to the organic waste a number of appropriate and sustainable crops would be included.

     (Q2)          How cost-effective are biomass and biofuels is bioenergy in comparison with other sources of renewable energy?

  26.  It is interesting that this question is so high up in the list. Surely, if the government is serious about improving the environment, then energy efficiency should feature more highly than the financial cost?

  27.  It is assumed that "other sources of renewable energy" refers to those which do not use biomass as a resource, in particularly those which take energy directly from the sun, moon and wind.

  28.  The different processes which convert biomass to bioenergy vary in their cost effectiveness. Anaerobic digestion, which produces renewable gas is generally thought to be the most cost effective as it needs less capital equipment, is cheaper to operate, and runs on waste rather than specially grown crops so the operator is paid for both what comes in and what is produced.

  29.  The figures for the cost of avoidance of CO2 equivalent is given in the EU Well to Wheels study[35] as in Euros per tonne of CO2 avoided compared with oil. This shows:
Bio-methane130
Fossil natural gas564
Ethanol from sugar beet342
Ethanol from wheat using CHP7,856
Biodiesel using RME243


  30.  The equivalent figures for wind energy production are not available, but the British Wind Energy Association quotes figures that the capital cost of wind power is between two and three times that of CCGT capacity. It also shows that carbon dioxide mitigation has been achieved only at a higher cost than that of a combined cycle gas turbine plant until very recently with the high rise in the cost of gas[36].

     (Q3)          How does bioenergy compare to other renewables, and with conventional fossil-fuels, in terms of carbon savings over their full life-cycle?

  31.  The EU Well to Wheels study shows very clearly that bio-methane (referred to CBG and biogas in the study) is the only fuel with a favourable fossil energy and GHG emissions footprint. The figures for other processes converting biomass to bioenergy are all available in this study.

  32.  The study shows that it cannot conclude that the processes for making biodiesel and bioethanol are energy efficient. "Taking into account the energy contained in the biomass resource one can calculate the total energy involved. This shows that biodiesel and bioethanol are several times higher than the fossil energy involved in the pathway itself and two to three times higher than the energy involved in making conventional fuels. These pathways are therefore fundamentally inefficient in the way they use biomass". It also concludes that the GHG balance is particularly uncertain because of nitrous oxide emissions form agriculture.

  33.  The EU Well to Wheels Study shows in Appendix 1 that much depends on the detail of the resource biomass and the process used and there are no simple answers. Examples from each process show the following well to wheel CO2 emission equivalents per km:
Biomethane from liquid manure:¸168 (note this is a negative figure)
Fossil natural gas  149
Biodiesel  160
Fossil Diesel  164
Bioethanol from sugar beet  190
Fossil Petrol  196


  34.  This shows that bio-methane will benefit the environment the most, with fossil natural gas coming second, followed by biodiesel, then fossil diesel, then bioethanol and fossil petrol coming last.

  35.  This confirms the view of the Natural Gas Vehicle Association that the route that the government should be encouraging is natural gas which is available today, with the aim of moving to bio-methane as soon as possible.

  36.  It is also worth remembering that natural gas and bio-methane are the most versatile fuels which can be used as vehicle fuel, or to create heat, or to create electricity.

     (Q4)          Not all biomass is equal—potential carbon savings depend on, for instance, farming practice. What can be done to ensure energy crops are sustainably produced?

  37.  Not only are different forms of biomass unequal, but the processes used to convert them into biofuels are also unequal. Different forms of biomass are suitable for different processes. Anaerobic digestion to create bio-methane works best with wet biomass. Combustion obviously prefers dry biomass. Both waste collection and farming practice obviously have an effect on the overall carbon savings, however as the waste has to be collected anyway this is the most favourable form of biomass.

  38.  It is a known fact that 85% of all food crops become waste, so the need to grow crops specially does not seem particularly necessary in the first instance, particularly given the negative impact on the environment of the current methods of farming some of the energy crops.

  39.  All forms of combustion to make energy from waste are unsustainable processes in that the nitrogen fertiliser value of the biomass is lost during combustion. Whether the process is incineration, CHP, pyrolysis, gasification or any other process which ends up in burning, if the feedstock contains any nitrogen, which could be used as a fertiliser, its replacement is required and this is achieved by a major input of fossil fuel. The problem is that the energy needed to replace the lost nitrogen fertiliser is often several times the electricity produced by the EfW plant.[37] The electricity cost of replacing the nitrogen plant food in the poultry litter burned can be between six and 21 times the electrical output of the plant.

  40.  Production of biodiesel and bioethanol are only sustainable when waste is used as the biomass resource rather than specially grown crops. If crops are to be grown specially then it is important that the most sustainable and energy efficient energy conversion process is used. Generally this will be anaerobic digestion for the production of bio-methane. Wheat for instance gives much better value in terms of the overall energy balance if it is converted into bio-methane than if it is converted into bioethanol using the present technologies.

  41.  Once all the biomass waste has been deployed, then it may be necessary to look at the production of specially grown crops. The production of this biomass needs to be sustainable and without damaging the environment. Sustainable standards need to be set if biomass crops are to be grown specially, possibly looking to the Soil Association for guidelines. The word sustainable must be used in its widest context, not just in terms of energy efficiency. The effect on the soil and particularly the loss of nutrients is most important.

  42.  Research is being carried out in the EU to determine which crops are best suited to anaerobic digestion under the EU programme Cropgen. One of the most interesting is grass, as this has been shown to be a good source of energy and it would be one of the most acceptable energy crops from the public's point of view.

     (Q5)          What impact will UK Government and EU actions have in increasing demand for, and production of, bioenergy?

  43.  The impact (if this means the result, rather than the impact on the environment) will depend on what actions are taken by the UK Government and the EU to increase demand for bioenergy. In the opinion of the NGVA government fiscal action should be to encourage the demand for clean and sustainable bioenergy. Providing this encouragement is long term and guaranteed, this will automatically increase the production and collection of biomass and will enable the different processing industries to develop their technologies.

  44.  It is well known that the production of bio-ethanol would be likely to become more energy efficient, but the same will apply to all the processes, including anaerobic digestion to produce bio-methane. The larger the market for all these fuels, the more investment there will be to improve the efficiencies of the processes.

  45.  Provided waste is encouraged to be used as the biomass resource then the impact will be to solve the problem of the country's organic waste problems.

  46.  Air quality will be substantially improved as well as to provide a clean biofuel.

  47.  At present, bio-methane is the most attractive option with its positive contribution to the environment and sustainable nature.

     (Q6)          What level of financial and policy support do bioenergy technologies require in order to achieve the Government's targets for renewable energy?

  48.  Bioenergy technologies need a minimal amount of support from the government when compared with the support which would be required for the nuclear industry, but mainly what is required is to have any financial incentives fixed at a set levels for sufficiently long periods so that industry is encouraged to invest. Historically other European countries have given longer term incentives than the UK government. The UK technologies are there, but the investors are hesitant as they need to see a long term fixed financial commitment from the government which at the moment is lacking or totally inadequate.

  49.  Enhanced capital allowances, fuel duty differentials, and renewables obligations are the classic incentives, but the government should consider other incentives which have already been proved to be effective in other countries. As far as vehicles powered by bioenergy are concerned, the following should be considered:

    Free parking with reserved spaces

    Special lanes on motorways, normally reserved for high occupancy vehicles

    Differential queues for taxis

    Fuel rebate for buses, lorries and vans

    Vehicle excise duty should be more in line with emissions

    Company car allowances should have a greater differential.

  50.  For example if the government were to reduce the tax on bio-methane, for a long and fixed period, the gas powered vehicle industry would flourish, filling stations would be built, the cars which already exist in the rest of the world in large numbers would become standard, and Britain would catch up with what the rest of the world is already doing. Reducing or eliminating environmentally unfriendly legislation such as the fuel duty rebate which rewarded the dirtiest and most wasteful fuel operators, and replacing this with something which encouraged biofuels would be essential. This particular legislation has lead to the appalling situation where the UK is about the only country in the world that has no new gas buses on order.

     (Q7)          What impact might an increase in energy crops in the UK and the rest of the EU have on biodiversity, production of food crops and land use and the environment more generally?

  51.  An increase in "energy crops" to provide a biomass resource, is bound to have a huge negative impact on biodiversity, particularly as many energy crops are not indigenous. Other disadvantages of producing energy crops:

    Use of water, which even for UK farming is a significant commodity. One tonne of grain requires at least 1,000 tonnes of water.

    Soil erosion as the whole crop is normally used as the biomass resource and is not usually ploughed back into the land to replace the organic material which makes up the soil structure. This means that the soil is either washed away by the rain or blown away by the wind.

    Loss of soil nutrients and fertility.

    Global warming itself threatens food production, so the land available for food production should be increased not decreased.

    Increased use of pesticides and other chemicals.

    Increased use of GM crops whose effect on the environment is not yet confirmed to be benign.

  52.  If energy crops are to be grown, then grass should be favoured over others as its negative impact is less, but it would be far more sensible to use the waste from the existing food crops. Farmers and the food processing industry should be encouraged to process their waste so that it can be used efficiently to create bioenergy and biofertiliser.

     (Q8)          (a)  Does bioenergy production constitute the best use of UK land for non-food crops?

  53.  It is difficult to compare recreational use of UK land with the growth of non-food crops or the growth of food crops. As explained above, it would be more sensible to use the waste from the existing food crops for bioenergy production, and leave the land for food production and recreational use.

    (b)  Should UK and EU policy focus on increasing domestic production of energy crops and biomass, or are there merits in importing biomass as a resource for producing bioenergy from outside the EU?

  54.  Neither. There should be no question whatever of importing any biomass while the UK still has enormous quantities of waste which are not being used. One of the principal advantages of using biomass as a resource for biofuels is the security and continuity of supply that comes from a home market.

  55.  UK and EU policy should focus on using the existing waste. When the stage is reached that this is all being used, but there is still a requirement for more biomass for the production of bioenergy, then native crops such as grass should be grown. It would also be ethically wrong to import specially grown biomass from overseas countries, thus depriving those countries of the chance to create their own bioenergy.

  56.  The International Energy Agency publication "Renewables for Power Generation, Status and Prospects 2003" says "The most economic forms of biomass are residues. These are the organic by-products of food, fibre and forest production. Anaerobic digestion schemes offer compelling solutions to waste disposal problems and produce bio-methane for energy use and a digestate that can serve as fertiliser or soil conditioner"

     (Q9)          What more can be done to make more efficient use, as an energy source, of the by-products of agriculture and forestry (eg wood waste and other organic waste)?

  57.  Government financial incentives such as enhanced capital allowances on equipment to produce bioenergy, duty rebates to encourage investment in all forms of biofuel production with large added incentives for those using waste rather than using specially grown crops as their biomass resource.

   (Q10)          What lessons can be learned from other countries' experience in the production and use of bioenergy?

  58.  Strong, clearly defined policy and government leadership is required with declared long term policies signed up to by all political parties which cannot be varied until speculative capital equipment is fully paid for and the technologies are all firmly established.

  59.  The UK is very far behind the rest of the world in acceptance of natural gas and bio-methane as the cleanest most environmentally friendly fuels whether as a vehicle fuel, for heat or to create electricity. This is entirely due to poor UK government policies such as the Fuel Duty Rebate. When UK policies are good, they are not set for long enough. As an example, the period of three years for a generous duty differential between diesel/petrol and natural gas or bio-methane has been shown to be too short to persuade decision managers or fleet operators to build filling stations and to place orders for new vehicles.

  60.  Mr Gordon Brown saying he will not give longer than three years for these duty differentials is just not an acceptable reason to ruin the UK's air quality and the nation's health. The same duty differential in Germany was for 16 years and has resulted in commitment to 1,000 gas filling stations being built by 2007 (with around 650 at present), and thousands of gas vehicles being purchased. In the UK three gas filling stations have been closed within the last few months, with no new gas stations being built and no new gas vehicles having been imported.

  61.  The UK has much to learn from both the developed and the developing countries. For example in Sri Lanka there are 4,000

[38]digesters producing bio-methane, however due to lack of continued government support, only 2,000

[39]are still operating. In India three million digesters are producing bio-methane and in Sweden more than 50% of the natural gas used is bio-methane and more cities operate on bio-methane than on fossil fuel natural gas. In these towns all the transport and the whole town, including tower blocks, use bio-methane instead of fossil fuel natural gas.

Natural Gas Vehicle Association (NGVA)

February 2006



34   Institute of Science in Society, Dream Farm Proposal. Back

35   "Well to Wheels Analysis of Future Automotive Fuels and Powertrains in the European Context" carried out for the European Commission by Concawe, the Joint Research Centre and the European Council for Research and Development. Back

36   British Wind Energy Association, Blowing Away the Myths. Back

37   Article in Materials Recycling Week 31 Aug 2001, based on research by Land Network and Professor Lynne Frostick head of Waste and Pollution Research Centre, University of Hull. Back

38   38 World Energy Council, Country reports. Back

39   39 IbidBack


 
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