To deal with your/my points in numerical order:

1 and 2: Being excited about the potential for biogas in the future does not mean we want to process it. There has never been any discussion within Blue-NG about moving into the production of biogas or building a processing site adjacent to any of our plants. It has never entered our thoughts.

3. You have made assumptions about a name, the land we need and a local business. The assumptions are incorrect. BHEAG has been contacted by the landowner concerned and can confirm this is the case.

4. We have permission to build up to 8 plants. That does not mean we will be building 8. Your calculations ignore the fact that we anticipate sourcing a considerable proportion of our fuel from RVO (recycled vegetable oil) which will reduce the acreage we need. I can not give you a precise figure on the percentage, because it is impossible for me to predict precisely the availability some 3-4 years ahead. At Beckton in London, we hope to source 25-30% of our fuel from RVO.

Latest figures (published this week by Agrimoney.com) are that the UK oilseed rape harvest this year will have 200-300,000 tonnes of oil available for export.
You are right that the transport sector also wants vegetable oil. What do you think is best for the country/climate? Putting vegetable oil into cars to prolong our selfish love affair with the car with its 18% efficiency? Or putting it into the world’s most efficient CHP plant with efficiency of over 90% and powering our homes/schools/hospitals/businesses?

As for smell. I have spoken again to our Air Quality consultants. This is not an issue.

I am happy to continue our engagement via this BHEAG commentary, but if you want to contact me directly drop me an e-mail at the above address.

Richard

Unfortunately my concerns arise due to a lack of confidence that your assertions and clarifications describe the full implications of this application. You want this development to be granted planning permission so no doubt you will be pushing its’ positives and down playing, or ignoring any negative. Spin is an all too frequent aspect of communication today, so please excuse my probing and questioning, it is just to try and get a fuller picture of the potential issues this proposal raises, and it is not directed at you personally, or your company.

Your Comment

1. I think there is some confusion here which I’m hoping I can clear up. Yes, we do think that in the medium term biogas will become available as alternative/additional to our vegetable oil and used cooking oil. This may well come from gas derived from household/agricultural waste.

What is wrong with that, especially if it could one day be piped in commercial quantities into our existing gas pipelines? Most environmentalists see biogas as cleaner and greener and infinitely preferable to simply burning waste to create heat and power.

2. There is no question whatsoever of the Blackrod site being used in the process of extracting biogas from waste. Lots of people asked about that, fearing our plant was a Trojan horse for further development. It is not. We are a renewable low-carbon generator, not a processor.

My Comment

It may be the case that no plans currently exist for the generation of syngas at Blackrod, but you cannot guarantee that these plans will not be developed at a later date. It could make good business sense to apply to expand the facility at a later date to put a household waste processing facility next to the current proposal. The syngas could be used as fuel or injected into the gas network. The National Grid has announced its plans for the processing of household waste, and the injection of upgraded syngas into the gas network.

I estimate you will pay about £28 million a year for the rape seed oil, and if it were me I would be looking for a cheaper fuel as soon as possible.

Your Comment

3. There is also confusion over the ownership of the land we would require to build our plant. Clearly, it would not be appropriate for me to breach confidentiality over a commercial negotiation with a landowner. Suffice to say, that it is my understanding that Bryan’s suggestion of a link to a local waste management firm is simply incorrect.

My Comment

My comment did not suggest a link existed but that the land was owned by the owners of a waste management company.

Your Comment

4. Yes we are profit motivated. We are a business and do not intend to run at a loss. But if profit was our only consideration, why would we be sourcing our oil from UK farmers, when it would be far, far cheaper for us to buy imported oil like palm?

We do not use cheaper palm oil because we do not regard it as sustainable and prefer to pay more AND support the UK rural economy. That is the right thing to do. (Check out the website Indexmundi which gives monthly updates on all sorts of commodity prices including rapeseed oil, palm oil, wheat, maize etc)

My Comment

Thank you for the link and you are quite right palm oil is cheaper at the moment than Rape seed oil, this would seem to equate to a price difference of 2p per Kwh (this includes the reduction in Palm oil needed due to its higher CV). My main concern though is your implication that locally sourced rape seed oil is sustainable, I have to admit I have my doubts.

I estimate the area of Rape seed required to supply the Blackrod proposal to be 216 square miles (This figure depend on the calorific value of rape seed oil, the litres per hectare, and other factors so I am sure that our figures will not tally exactly).

Add this to the needs of the other 7 facilities I believe Blue -NG are proposing and you have a very large requirement.

Andrew Mercer stated last year that he expected to be generating 1GW of renewable energy (this would require ~6500 square miles) in the next 5 years and 10 GW (~65000 square miles) by 2020, that’s a lot of land. The area of Lancashire is 1,200 square miles and England’s is 50,085 square miles.

You are not the only company that has identified the potential business opportunities presented by rape seed oil. I have noticed a number of other CHP facilities together with plans to increase Biodiesel production. These emerging requirements, your needs, and the current users of rape seed oil, will no doubt exceed the currently available supplies.

Your Comment

5. One final point. Don’t worry about the smell Bryan. There would be no smell due to the high temperatures involved and the mitigation measures we would install. If we do not do as we say we will do, we will be closed down.

My Comment

I don’t think that if odours are emitted by the facility it would be shut down. You will have just spent a very large sum, and you will be looking forward to getting ~£30.6 million in ROC payments, and ~£15 million in electricity sales (assuming £50 per MWh) a year. Any inconvenience to Blackrod would therefore seem to be of little importance to your company.

It is unlikely that the Environment Agency would be able to do anything as this extract from their document H4 Odour Guidance states

“If problems do occur, or are likely to, you must take the appropriate actions to prevent them or minimise them when prevention is not practicable. The measures that are appropriate will depend on your industry sector/regime and your individual circumstances.

o the size of exposed population;
o the cost or feasibility of reducing the odour and the need to manage public expectation that some activities will not be entirely free of odour”

They would only close you down if the problem was really bad. Minor inconvenience would not be considered to be unacceptable. Your confidence on emissions from SVO may be well placed, but what about RVO, RVO/SVO, and the future fuels?

Now you say that “We have not declined future engagement and continue to have a dialogue.”

That’s good news.

There is also confusion over the ownership of the land we would require to build our plant. Clearly, it would not be appropriate for me to breach confidentiality over a commercial negotiation with a landowner. Suffice to say, that it is my understanding that Bryan’s suggestion of a link to a local waste management firm is simply incorrect.

Yes we are profit motivated. We are a business and do not intend to run at a loss. But if profit was our only consideration, why would we be sourcing our oil from UK farmers, when it would be far, far cheaper for us to buy imported oil like palm? We do not use cheaper palm oil because we do not regard it as sustainable and prefer to pay more AND support the UK rural economy. That is the right thing to do. (Check out the website Indexmundi which gives monthly updates on all sorts of commodity prices including rapeseed oil, palm oil, wheat, maize etc)

One final point. Don’t worry about the smell Bryan. There would be no smell due to the high temperatures involved and the mitigation measures we would install. If we do not do as we say we will do, we will be closed down.

Richard Lyddon
Head of Communications
Blue-NG

“Blue-NG is very disappointed that BHEAG declined to meet with us this week and indicated they do not want any further engagement. We would have welcomed the opportunity to demonstrate that we are part of the mix of renewables that need to be developed to tackle climate change and keep the lights on in a sustainable way. To state that we make climate change worse flies in the face of evidence to the contrary which has been independently researched and audited by among others, a consultancy that advises the government in these matters. We do not use palm oil and our sustainable procurement policy was drawn up with the help of Greenpeace and not only meets, but exceeds UK and EU sustainability standards.

Blue-NG has yet to submit a detailed planning application. We are currently considering the points and concerns raised in our public consultation process. These will be taken into consideration when we submit our planning application in due course.

The figure quoted for land use does not take into account the likelihood that up to 25% of the fuel will be used cooking oil not oil from rape. I anticipate that by the time of our final application, the amount of land needed to fuel a Blackrod plant will be far, far smaller than that quoted. Besides, oilseed rape is an established break crop used in 3 to 4 year cycles of crop rotation. Given that 86% of the crop will go straight back into the food chain (as fertiliser or animal feed) and 13% used for our oil, what is the issue with a crop where 99% of the plant is used either for food or energy production?

I would urge BHEAG, local residents and their elected representatives to study our final application in detail before making their minds up and to continue to engage with us. I am confident they will recognise that we have taken into account local opinion.”

Richard Lyddon
Head of Communications

My advice would be to get them to countersign all their promises in triplicate, and then just don’t believe them.

They are profit motivated so they will want the cheapest fuel they can get.

Is it me or is it too much of a coincidence that the land proposed is owned by the owners of a local waste management site.

Something does not smell right about this proposal, and if we are not careful neither will the air in Blackrod.