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EUA Position Statement for Biogas

Policy Statement

Biogas December 2012

Page 1 December 2012

EUA Position Statement for Biogas

EUA Policy Position – Biogas Background UK Government has recognised in its recent ‘Bioenergy Strategy’ the potential contribution of biofuels in helping the UK meets its renewable energy targets for 2020 and its carbon reduction commitment for 2050. Bioenergy has a role to play in the three key sectors of electricity, heat and transport. This policy paper addresses the issues surrounding the generation and use of ‘biomethane’, i.e. biogas that has been generated from biodegradable wastes and upgraded to an appropriate specification for pipeline distribution and use. Furthermore, the policy position here deals predominantly with biomethane derived from AD (anaerobic digestion plant) rather than gasification of bio-feedstocks, although both have their place in the energy mix. The benefits of biofuels are well known – in addition to their obvious renewable origins they provide a continuous supply of energy not being dependent on the wind nor solar and tidal intermittency. Concerns exist however over future access to truly sustainable supplies of feedstock and whether full carbon accounting has been conducted to include, for example, indirect impacts on land use change. Competition for secure food crops is also a concern. Anaerobic digestion (AD) of organic residues is not new - it has been practised for over a hundred years to process sewage sludge into a safe digestate – and there are currently 146 sewage sludge plants in operation in the UK. Historically, produced methane gas was flared; current practice is to capture the produced biogas and burn it in reciprocating engines to produce power for local and export purposes. Since there is little requirement for heat at the point of production, overall thermal efficiencies are limited to around 35%. With additional capital investment in gas upgrading plant to remove excess carbon dioxide and trace hydrogen sulphide, the gas can be brought up to that meeting pipeline quality (BIOMETHANE) as defined in the Gas Safety (Management) Regulations. This also requires control of the oxygen level to 0.2% and slight upgrading of the calorific value (using propane injection). These are constraints imposed by pipeline corrosion and customer billing requirements respectively. Two small scale plants at Didcot (sewage treatment) and at Adnams Brewery (brewery and food waste) are now grid-connected, although derogation on oxygen level to 0.5% was granted to allow these demonstrations to proceed. A number of applications for further grid-connected plants are being considered by network operators.

Contribution of Biomethane to Renewable Energy Targets With 81% of residential heat being provided by natural gas being reliably delivered by an existing nationwide infrastructure of pipelines, it is quite foolish to believe those that say the gas network has no use from 2030. Combined with home insulation improvements, condensing boiler replacement schemes, injection of waste-derived biomethane into the distribution grid makes perfect sense - renewable heat ‘on-tap’. UK Government has focused too much attention on the projected use of heat pumps; yes they make sense in purpose designed new dwellings or off-grid properties, together with Page 2 December 2012

EUA Position Statement for Biogas

gas-fired units to meet peak heating demand, but for existing dwellings gas will remain the space heating fuel of choice. The rewiring of the distribution network required to deliver sufficient UK-wide capacity to retrofit heat pumps is just not tenable; further, heat pumps cannot deliver the necessary temperature lift in the coldest days of the year. If you want heat in the home, use gas. National Grid has reviewed the potential contribution of biogas to domestic heat and has placed an upper bound on this at 50% (some 190 TWh/year). Of course this includes all technologies and assumes a ready supply of waste and crops to feed the production plants, and is in itself an ambitious target. In their revised ‘gone green’ scenario to 2030 a more credible 50 TWh of biogas heat is assumed (20 TWh in 2020) representing some 17% of domestic heat demand (300 TWh) in 2030. This figure correlates well with wider European Studies showing potential to be 1 TWh per million head of population. This Europe-wide level represents some 30% European gas production and 10% of total gas consumption. Conversely, the use of all biomethane produced as a vehicle fuel would deliver the EU’s 10% of transport fuels from renewable sources in a single step. DECC’s target of 7 TWh renewable heat by 2020 is in our view not ambitious enough. Targets for use of biomethane as a vehicle fuel in the UK should also be revisited, particularly in light of the potential to integrate waste delivery and biomethane production. Progress to this target level is not without its own challenges – 50 TWh would require some 250 plants like the one operating at Didcot (0.2 TWh/year output), in turn requiring efficient planning, grid connection processes, and supply chains.

UK Gas Quality Requirements Through its Technical Panels EUA is continuing to liaise with UK government departments to ensure that appropriate “gas quality” is ensured for any biomethane entering the mains gas supply. Most of the existing gas quality requirements in Gas Safety (Management) Regulations [GS(M)R] and Network Entry Agreements (NEAs) will continue to apply, however some “derogations” may be appropriate to facilitate the development of UK biomethane resources. EUA would urge that any such derogations are made in consultation with appliance manufacturers and other industry stakeholders to ensure that operation, efficiency and safety of appliances and other apparatus (such as gas meters) is not affected, especially near major points of injection. Cleaning the biogas to deliver an oxygen content of 0.2% compliant with GS(M)R regulations can place onerous capital cost burden on the clean-up plant. In Europe gas containing up to 2% oxygen can be admitted to the gas grid. Since the regulation on allowed oxygen level is related to corrosion issues in metallic systems (and we are replacing large sections of the low pressure network with PE), we would encourage, as is being proposed, an early network-wide derogation to 1% allowed oxygen with specific risk-assessed cases to 2% where required. We would encourage also the downstream sector of the industry to review any performance issues with domestic combustion equipment in the event that the oxygen content of the piped gas varies in the region 0 to 2%. Attention should also be paid to the potential effects on appliances and other apparatus of any “minor components” not presently covered by GS(M)R and NEAs. Responses have already been made to a recent consultation on a “Draft Quality Protocol” for biomethane, raising concern over the potential presence of minor components such as siloxanes (a range of organic silicon compounds which can generate solid residues of silica on combustion). EUA would urge further discussion of these concerns with other regulatory and policymaking bodies involved in the development of requirements for biomethane. Page 3 December 2012

EUA Position Statement for Biogas

Integrated Waste Approaches The successful deployment of grid-connected biomethane requires not only good energy policy but also complementary Agricultural and Waste policy. There is clearly some way to go in delivering adequate waste collection policies and further work is needed to promote the safe use of the by-products of the AD process as fertilisers and ground improvers. Biomethane can be used as a heavy goods vehicle fuel to displace diesel, and integrated schemes of waste delivery vehicles running on biomethane seems an obvious synergy.

Innovation Requirements As the AD process has grown up as a method of treating farm and sewage waste, more innovative approaches for overall process efficiency and cost have not kept pace. RHI is certainly helping developers make the economic case but further R&D is required to improve biological process enhancement, reduce gas clean-up costs, and understand the best feedstocks for treatment. Recent work to modularise the grid connection, metering and odourisation plant will deliver real benefits in overall cost of equipment. Ofgem should earmark specific large scale demonstration funds in the Network Innovation Competition for gas (from 2014) as a way to promote innovation in the sector.

Page 4 December 2012

EUA Position Statement for Biogas

Summary Policy Position on Biogas 

Biomethane-to-grid is an ideal renewable, reliable and secure source of energy delivering not only the potential for near-zero carbon heat, but as a solution to organic waste in landfill and as a source of natural fertilisers.

Biogas should not be used to generate electricity unless there is an effective sink for the heat co-produced. The forward reviews of ROCs/FIT/RHI should embody this principle.

More ambitious near term targets should be set for biomethane-to-grid projects by 2020, with an objective of realising 20% of residential heat demand by 2030.

As an essential way of capital cost reduction, EUA supports proposed changes or derogation to the existing GS(M)R that caps O2 content at 0.2%. For completeness however the downstream industry should review any potential risks arising from this proposal.

Integrated policy in energy, agriculture and waste is a prerequisite for successful large scale deployment of biomethane-to-grid projects.

The potential contribution of biomethane as (heavy goods) vehicle fuel should not be discounted as a contributor to the sub-target of 10% for renewable transport fuels by 2020.

The industry has opportunity to invest significant innovation monies to perform large scale demonstration of this technology as part of Ofgem’s Network Innovation Competition for gas.

Page 5 December 2012

EUA Position Statement for Biogas

Supporting Notes: References: 1. The Potential for Renewable Gas in the UK – A Paper by National Grid, January 2009. 2. SBGI Position Paper on Gas from Renewable Sources, July 2009 (SBGI files). 3. UK Biomethane to Grid Developments, Shell Customer Day, John Baldwin, CNG Services Ltd, October 2011. 4. EUA Position Paper ‘Role of Gas in the Future Energy Mix’, May 2012 (EUA files) 5. The Future of Heating: A strategic Framework for the Future of Heat, DECC, March 2012. 6. Bioenergy Review, Committee on Climate Change, Dec 2011 7. WRAP Organic Waste Market Situation Report (hard copy only). 8. AD Strategy and Action Plan, DEFRA, June 2011. 9. UK Bioenergy Strategy, DECC April 2012 10. AEBIOM – European Biomass Association, A Biogas Roadmap For Europe.

Conversion Economics Each tonne of food waste can generate 100-150 m3 of biogas (or 60 – 90 m3 of biomethane when upgraded), 0.83 tonne of digestate. Potential to generate 300 kWh of electricity. If this is valued at the price of other renewable enrgies, £100/MWh, then this is £30 per tonne of input food waste. ROCs could add 50%. (ref 7). Suitable and sustainable markets for digestate are required (liquid to fertiliser, solid as soil improver). Biomethane with RHI gives same rate of return as biogas with ROCs (ref 3). RHI subsidy is 6.7p/kWh, value of gas is ~ 2p/kWh Feed in tariff review: The new tariffs for AD will be:

Page 6 December 2012

EUA Position Statement for Biogas

≤250kW: The current rate of 14.7 p/kWh will remain unchanged

>250 - ≤500kW: The current rate of 13.6 p/kWh will remain unchanged

>500 - ≤5000kW: The current rate of 9.9 p/kWh will decrease to 8.96 p/kWh from December 2012

Heat Market Total heat demand in 2010 was 712 TWh. Decarbonising heat supply is likely to be a vital part of any scenario that successfully delivers the fourth carbon budget and renewable heat is expected to make an important contribution to meeting the EU renewable energy target in 2020. Although within the wider options for decarbonising the heat sector, bioenergy is expected to play a relatively marginal role, its contribution will be key in filling the energy needs of vital segments that could be hard to decarbonise in other ways, such as high temperature industrial processes. A role for biogas that can be used in space heating in the medium to short term as well as in high temperature process heating in the longer term. In the short-term this is likely to be driven by biomethane injection from AD processes but in the medium term there may be scope for gasification derived bio-syngas; (ref 9) Today biomass providing 1% of heat; could be 6% by 2020 (ref 9) Domestic market is 450 TWh/year, 81% gas-fired (63% of heat requirement is residential) AD could deliver 3 – 5 TWh by 2020. (ref 8) Strategy for AD (ref 8) AD used to produce energy is classified as step 4 (other recovery) in the 5-step revised waste framework directive; under certain circumstances can count as ‘recycling’; AD is a better solution for food waste for example. AD is continuous, not dependent for example on wind, tidal or solar cycles. Benefits of AD well described in para 24 of exec summary of ref 8. 54 operational AD sites excluding sewage sludge (32 on farm, 22 off-farm); 2 injecting biomethane to grid. 35 MWe current generating capcity. 146 sewage sludge treatment plants; 110 MWe output. Total 145 MWe, 1.08 TWh total capacity. Forecast waste available: 5mte of food, 20 – 60mte of animal waste. Translates to 3 – 5 TWh only. Need agricultural crops to go beyond this.

Page 7 December 2012

EUA Position Statement for Biogas

Helps meet both renewable energy targets and waste reduction targets. DECC is currently exploring the possibility of a gas licence exemption for onshore gas production. This should make it easier to inject biomethane from an AD plant into the gas grid. The existing regulatory framework for AD needs to ensure that the balance between encouraging growth of the industry and the requirement to protect human health and the environment (including animal health) is well understood. However, there is a perception that the existing regulatory framework that controls the use of AD in England and Wales poses a number of regulatory challenges for AD operators of all scales. Action 37 calls on trade associations to promote the benefits of grid-connected biomethane. Bioenergy Review (ref 9) This responds to earlier CCC report, particularly on issues relating to real carbon reduction, and impact on food security. The pre-eminent concern of the UK Government in bioenergy policy is that bioenergy offers a genuine reduction in greenhouse gas emissions, that this reduction is cost effective and that the biomass is produced sustainably.

Bioenergy 8 -11% of primary energy by 2020; but only 12% by 2050? View – can’t deliver sustainable feed stocks beyond this. Biomethane Potential (NG view, ref 1) A very bullish view – up to 50% of residential gas demand; NG accept probably unobtainable. Their later Gone Green scenario has 20 TWh by 2020 and 50 TWh by 2030. European Potential Magic figure for potential is 1 TWh per million population. This relates to % land use and availability of waste streams. 500 m people in EU27. 500 TWh equates to 30% European gas production and 10% of total gas consumption. Conversely, the use of all biomethane produced as a vehicle fuel would deliver the EU’s 10% of transport fuels from renewable sources in a single step. Didcot Biomethane Plant UK’s first project (Oct 2010) Thames water treatment works. Connected to SGN network. 100 m3/h (21 mcm/year) Adnams Biomethane Plant Located at Southwold. First food waste plant. Connected to NGG network. Will process up to 25,000 te per annum of waste producing 1.2 mcm of biomethane (i.e 1 te of waste delivering 48 m3 of biomethane) Operated by Adnams Bioenergy. Page 8 December 2012

EUA Position Statement for Biogas

Fairfield BioEnergy plant in Stockport (due Autumn 2012) First to be completed under RHI scheme. Twice the size of Southwold plant.

Page 9 December 2012

EUA Policy Statement - Biogas  

Biofuels will help the UK meet its renewable energy targets for 2020 and its carbon reduction commitment for 2050. Bioenergy has a role to...

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