Beta Analytic Comments On Biodiesel, Glycerol, And The Renewables Obligation

Beta Analytic Inc. (Headquarters) 4985 SW 74 Court Miami, Florida 33155 USA Tel: (1) 305-662-7760 Fax: (1) 305-663-0964 Email: [email protected] Web Site: http://www.betalabservices.com/

Beta Analytic Limited London Bioscience Innovation Centre 2 Royal College Street London NW10NH United Kingdom Tel: (44) 207 617 7490 Fax: (44) 207 160 5350 Email: [email protected]

Beta Public Comment on Biodiesel, Glycerol, and the Renewables Obligation Mr. Fletcher, Please find below our answers to your questions for the biodiesel, glycerol and renewables obligation consultation. Chapter 1, Question 1: Chapter 1 summarises the most frequently used manufacture process for Biodiesel. Are you aware of any techniques used, available or foresee in the near future that should be taken into account? We are not aware of any future techniques that need to be taken into account. Chapter 1, Question 2: Can any further evidence be provided to show that the source of the transferred hydrogen atoms within the glycerol cannot come from the methane used in the manufacture of the methanol? We believe that this would not be possible. On the other hand, we believe that radiocarbon dating can be used to determine whether the glycerol is derived from fossil fuels, such as methanol made from fossil fuel methane. By analyzing the carbon atoms with radiocarbon dating of both the biodiesel and the glycerol produced in the manufacturing process, one can easily determine whether glycerol might be coming from fossil fuel derived methane. Radiocarbon dating is regularly used to determine the biomass percentage of biofuels such as biodiesel. Consequently, there is no reason why this method cannot be used to address whether glycerol is made from fossil fuel components. In fact, radiocarbon dating has been standardized as an analytical method called ASTM D6866 precisely for this type of determination. Radiocarbon dating has been used for decades for dating archaeological artifacts. The same principles of dating (i.e. analysis of the carbon 14 atom) can also be used to measure the biomass component of materials. In effect, biomass contains a well-characterized amount of carbon 14 that is easily distinguished from other materials such as fossil fuels that do not contain any carbon 14. Since the amount of carbon 14 in biomass is well known, a percentage of biomass carbon can be calculated easily from the overall carbon atoms in the sample. Although ASTM D6866 is now used throughout the world to measure biomass carbon, the origins of the method are American. It was written at the request of the USDA to satisfy legislation requiring Federal agencies to give preferred procurement to manufacturers using the greatest amount of biomass in their products (per the Farm Security and Rural Investment act of 2002). It was quickly established that radiocarbon dating was the only viable accurate technique to make the determination of the biomass percentage. A working standard of radiocarbon dating for industrial use was completed in 2004 and is now cited in US Federal Law (7 CFR part 2902). Our firm, Beta Analytic, has been in direct contact for the past year and half with OFGEM with regard to their Renewable Obligation Certificate program for Energy from Waste Combined Heat and Power plants. A study was commissioned on behalf of OFGEM by the Renewable Energy

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Association, with Beta Analytic, Columbia University and Fichtner's participation to demonstrate the viability of radiocarbon dating for determining the biomass fraction of materials. I have attached to this email a copy of this study. The study clearly shows that radiocarbon can accurately determine the biomass fraction of different materials (see in particular page 20). Furthermore, the study demonstrates that radiocarbon dating can be used to determine the energy produced from biomass. The same principals and findings in this report can be used to bolster the use of radiocarbon dating as a viable analytical method for verifying the biomass fraction of biodiesel and glycerol. Chapter 3, Question 1: Are there any circumstances in which Biodiesel (produced using methanol derived from natural gas) would not contain atoms from the natural gas? In general, we believe that this would not be possible. On the other hand, as stated above, radiocarbon dating can easily determine whether biodiesel is made with fossil fuel feedstocks. Precision of the method is excellent with an error of less than +/- 0.3%. We therefore believe that radiocarbon dating can easily address whether biodiesel is manufactured with methanol derived from natural gas. Chapter 3, Question 2: What are your views on this approach to the eligibility of Biodiesel? As stated above, we believe that radiocarbon dating using the standardized method ASTM D6866 can easily address the issue of eligibility of biodiesel. Chapter 4, Question 1: What are your views on the proposed interpretations? We believe some of the interpretations are overly restrictive since radiocarbon dating can address some, if not all the concerns of the biomass fraction of glycerol. Chapter 4, Question 2: Do you agree with our preferred option of adopting the total exclusion interpretation? We believe that this option is overly restrictive considering that radiocarbon dating can address some, if not all the concerns of the biomass fraction of glycerol. Chapter 4, Question 3: Do you agree with our assessment of the benefits and consequences of each interpretation, and do you foresee any others for either interpretation provided in this chapter? Radiocarbon dating is a cost effective method to verify whether glycerol is made with fossil fuel feedstocks. We therefore believe that the total exclusion suggestion is too restrictive since a proven analytical is available for determining the biomass fraction of glycerol. Chapter 4, Question 4: Are there any other valid interpretations that should be evaluated in order to determine Ofgem's policy on glycerol? Yes. Ofgem should take into account the composition of the carbon atoms during the manufacture of both biodiesel and glycerol to make the proper interpretation whether to allow the use of glycerol in the Renewable Obligations program. As stated above, radiocarbon can be used to make this determination. Chapter 4, Question 5 (glycerol's use in Anaerobic Digestion): Would there be any impact on Anaerobic Digestion if either interpretation for glycerol was adopted? If so would this be significant?

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We believe that it would have an impact, but we are not in the measure to attest how large would be the impact. Chapter 4, Question 6 (glycerol's use in Anaerobic Digestion): Is there any information that would show glycerol's methane producing ability, which Ofgem could use to form our policy and allow us to determine the renewable fraction of the biogas from an anaerobic digester using glycerol? Yes. Radiocarbon dating can easily determine the renewable fraction of the biogas from an anaerobic digester using glycerol. See the answer to question 2, chapter 1 for an explanation of radiocarbon dating. Sincerely,

Thierry Sam Tamers Director

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