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:
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:
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:
Bio-diesels including FAME (Fatty Acid
Methyl Esters)
Bio-methane also known as renewable
natural gas or biogas
Ethanol
Bioethanol including MT/ETBE
Methanol, also known as wood alcohol
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:
| pyrolysis | produces heat and liquid bio-oil fuel
|
| gasification | produces heat and syngas fuel
|
| anaerobic digestion | produces bio-methane fuel
|
| transesterification | produces liquid biodiesel fuel
|
| fermentation and distillation | produces liquid alcohol fuel
|
| combustion | produces high-grade heat which can be used to raise steam, used for making electricity
|
| CHP | produces 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-methane | 130 |
| Fossil natural gas | 564 |
| Ethanol from sugar beet | 342
|
| Ethanol from wheat using CHP | 7,856
|
| Biodiesel using RME | 243 |
| |
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 Ibid. Back
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