Bio-SNG - CNG Services

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BIO-SNG FEASIBILITY STUDY – ESTABLISHMENT OF A REGIONAL PROJECTthe injection of methane from biogenic origins into the gas network and requires member states tofacilitate this activity. The RED sets specific sectoral targets including the achievement of 10% renewableenergy in surface transportation systems (a possible use of Bio-SNG) and encourages the use of wastederivedmaterials by proposing double incentives for the use of energy derived from biogenic wastes.3.2 ENERGY FROM WASTE REGULATIONS AND ISSUESThe use of waste derived fuels invokes additional regulatory considerations associated with the WasteIncineration Directive (WID) as well as the need to assure the bio-energy contribution to the energyrelease from mixed fossil / non fossil components. The drafting of the WID and its interpretation intoEnglish or Scottish law presumes that waste derived fuels would be burned in an incineration plant. Thispresumption leads to some difficulties when wastes are used in alternative energy schemes that were notanticipated at the time of the WID drafting. Firstly the question of when a recovered material ceases to bea waste continues to be a grey area. On the one hand recycled paper is considered to be recoveredwhen it is returned to raw paper pulp – the pulp then being no longer subject to regulation as a waste.The recovery of waste paper as a fuel, however, does not benefit from this interpretation; waste-derivedfuels are still considered to be wastes – irrespective of their use and their intrinsic properties. Accordinglyenergy plants fuelled by waste-derived fuels are subject to regulation under the WID, the syngasproduced by a gasifier still being regarded by the Environment Agency as a waste 12 . The prevailingwisdom from the Environment Agency is that the gas would continue to be a waste up to the point whereit is “recovered” – i.e. burned. At face value this means that if Bio-SNG was to be produced from wasteand burned in a domestic heating appliance then the domestic heating appliance would need to complywith the requirements of the WID. This is clearly a nonsense that would need to be formally andunambiguously resolved before waste-derived fuels could be used in the production of Bio-SNG.Accounting for the energy contributions from the fossil and non-fossil components of waste derived fuels(i.e. miscellaneous biomass and various plastic rejects) is necessary in order to gain accreditation forsupport for the bio-energy fraction under any of the renewables incentives listed above. To date this hasbeen a concern predominantly in the waste to electricity sector, but it is clearly going to be equallyimportant in a Bio-SNG development. Where a 100% biomass fuel is used it is a relatively simple matterto assure the bio-energy content of the fuel and this can be achieved via an agreed fuel qualitymanagement plan. With a heterogeneous waste derived fuel there are two possible methods to assessbio-energy content in the fuel – sampling and physical separation followed by classification and weighing,or selective dissolution of biomass. Both require a sampling programme, which, given the inherentvariability of waste-derived fuels is subject to significant error bands and uncertainty unless a largenumber of samples is taken into consideration. Even then it would be practically impossible to guaranteehow much of the bio-energy had reported to the final Bio-SNG product stream, and how much had beenassociated with incidental process heat losses. The practical way to measure the bio-energy content of12 A recent EU Ruling at Lahti has set a precedent that a syngas may no longer be a waste. Whilst this is underconsideration in the UK, no such formal policy position has been set out as of the date of this report.18
BIO-SNG FEASIBILITY STUDY – ESTABLISHMENT OF A REGIONAL PROJECTthe product SNG would be to use C 14 based techniques similar to those which are at present undergoingdemonstration to Ofgem in facilities generating electricity from wastes. Whilst the C 14 methodology fordetermination of bio-energy content appears to be the favoured approach, it must be appreciated thatthere is still some work to be undertaken before it is finally accepted by Ofgem as an appropriatemechanism for accreditation of renewable energy content. Utilisation of C 14 in Bio-SNG production fromheterogeneous fuels would entail some further work beyond that, but for Bio-SNG it is probably the onlypractical methodology for establishing bio-energy contribution from a heterogeneous fuel.Electricity plants running on waste-derived fuels can, under certain circumstances qualify for enhancedcapital allowances against corporation tax but this will also require operators to give evidence of biogenicenergy contribution for which C 14 based systems would be ideally suited. It is also unclear if such benefitscould accrue to Bio-SNG facilities.3.3 EMISSIONS TRADINGUnder the European Emissions trading Scheme (Eu ETS) all power plants with a thermal rating of greaterthan 20MW are required to register and report their GHG emissions. The implementation of the ETS isPhased from its initial introduction in 2005 (Phase 1), with Phase 2 running from 2008 to 2012 whereafterthe third and ultimate scope of the ETS will be imposed. The objective of the Eu ETS is to set a cap ongross Eu GHG emissions reducing annually from a figure of 1927m tonnes CO 2 equivalent in 2013; thisfigure being shared, by a process of negotiation, between the member states. In each phase and year ofthe implementation a progressive lowering of the free carbon allowances will be imposed, obligingthereby the operators to progressively reduce their own GHG emissions or else to buy surplus allowancesin the market from those with a surfeit of allowances. Whilst all thermal power plants of greater than20MWth are required to register under the Eu ETS, certain types of plant are exempt from the need tolimit their annual GHG emissions; these include facilities running on pure biomass. It will be apparenttherefore that a Bio-SNG plant running on pure biomass will not be required to obtain emissions permitsunder the Eu ETS, but where a waste-derived fuel that includes some fossil carbon is used then the ETSbecomes not only a regulatory consideration but fossil carbon emissions need to be accounted for andmeasured. This may require a particular treatment because some of the energy release will be local, withthe remainder being consigned to the pipeline. It should be noted that “Municipal facilities” are exemptfrom the provisions of the Eu ETS, hence a plant operating primarily to deliver a municipal wastemanagement service ought to be exempt. The status of a potential Bio-SNG plant appears to besomewhat obscure with respect to the Eu ETS, therefore it is recommended that early in the developmentprogramme clarification should be sought concerning whether such a plant would be eligible / liable, andalso how the question of a percentage of fossil carbon in the feedstock should be handled. (Note that theBio-SNG plant will be a direct producer of carbon dioxide resulting from acid gas removal post shift andpre methanation reactions. With a waste-derived fuel some of this will have a fossil origin.)19
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