Low Carbon Fuels Strategy Call for Ideas: Response from Coryton

May 13, 2022

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(Coryton) ... Consequently, Coryton firmly believes that we need to move away from the focusing on the tailpipe emissions as this effectively
1) ignores the upstream carbon emissions associated with the manufacture of battery packs, the production of hydrogen and the carbon intensity of the charging grid;
2) simultaneously ignores the carbon savings associated with low carbon fuels.

We strongly recommend a shift to a more life-cycle based approach so that more scientific and evidence-based polices can be developed.

Whilst we understand that this is a very challenging shift in paradigm for the government, we are in a climate emergency and so do
not believe that being “too hard” is a good enough reason not to try. If we are to genuinely tackle GHG emissions and climate change we must take an overall life-cycle approach.

Coryton’s response to the call for ideas is focused where Coryton’s experience or expertise can support the ramp-up of the adoption of sustainable fuels and reduce GHG emissions. It is laid out and numbered according to the questions in each chapter in the call for ideas.

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i. How can the low carbon fuels strategy best improve certainty about the deployment of low carbon fuels to support the decarbonisation of the transport sector and the growth of this industry in the UK?

Coryton believe that the best way to improve certainty is to enable the carbon savings associated with sustainable fuels visibly “count”. By focusing on tailpipe emissions only, we effectively draw the system boundary around the vehicle when it is in use and only take into the account the emissions produced as it is driven. The risk associated with this arbitrary boundary is that it simply shifts the GHG emissions somewhere else in the value chain where it is not accounted for. In the case of battery electric vehicles (BEV), the additional GHG emissions come from the manufacture of the battery packs (specifically the individual cells) and the carbon-intensity of the charging grid.

The same is true for hydrogen fuel cell electric vehicles (FCEV) (as they also have battery packs) with the additional issue associated with the carbon intensity of the hydrogen production (see vii). We find ourselves in a perverse situation where a substantial part of the GHG emissions from a BEV or FCEV are not accounted for as only tailpipe emissions are considered and, by the same token, all the
savings in GHG emissions from sustainable fuels are also ignored. This leads to a very distorted, and ultimately damaging, view of the world.

In the end, there is only one system boundary that matters and that is the planet, hence Coryton strongly recommends a shift to a more life-cycle based approach (well-to-wheel (WTW) as a minimum) so that more scientific and evidence-based polices can be developed.

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iii. Does this chapter accurately capture key trends, opportunities and risks in terms of low carbon fuels demand? If no, please expand on any aspects that you think are missing or inaccurate, or require further exploration.

Coryton basically agree with this chapter but with three main exceptions; the concept of blend walls, the opportunities for petrol/gasoline fuels and the business case.

The current blend walls at E10 and B7 for gasoline and diesel respectively does NOT mean that this is the maximum amount of low carbon content that can be in the fuel. It means that the maximum amount of specifically bioethanol in EN228 gasoline can be 10% in order to maintain as much backward compatibility with the existing fleet as possible. However, any additional bioethanol reserves could be further processed into biogasoline using the ethanol-to-gasoline (ETG) process.

This effectively means that biogasoline can be blended into fossil-based gasoline without exceeding the E10 blend wall. However, there are no ETG plants in the UK and our supply comes from Europe.

Similarly for Diesel. B7 does not mean that the maximum sustainable content in diesel is 7%, simply that the maximum amount of biodiesel (FAME) in the blend is limited to 7% Sustainable paraffinic diesels, such as those made by the HVO process, can be blended into the fuel on the other side of the blend wall, ultimately enabling a B7, EN590 fuel to contain up to 100% sustainable components.

Much of the focus of the chapter is on the heavier fuels such as diesel and aviation fuel. However, with the shift to more petrol-powered passenger cars and most hybrid/plug-in hybrid vehicles being offered for sale with petrol engines, we cannot afford to ignore gasoline fuels.

As mentioned above, the maximum ethanol content in pump gasoline at the moment is limited to 10% and this is reasonable in order to maintain efficacy in addressing the existing fleet. However, processing further ethanol by dehydrating it and then growing longer chain hydrocarbons enables the production of biogasoline.

At Coryton, we have developed a 2nd generation EN228 biogasoline using agricultural waste with almost 100% renewable content and GHG savings in excess of 85% (on a WTW basis) compared to fossil gasoline.

2Regarding the business case there are two main issues; market awareness and scale. The benefits of sustainable fuels need to much more widely promoted and incentivised - the government need to take an active part in this. Once people are aware that these fuels exist, demand will increase significantly. However, these fuels are currently more expensive than their fossil counterparts and are not available in large volumes. The industry needs to invest and scale-up in order to drive costs down and widen adoption, but where is the incentive to do this? The carbon savings do not count thus no value chain is created for producing/using sustainable fuels.

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xviii. Does this chapter capture key trends, opportunities, and risks in terms of policy framework? If no, please expand on any aspects that you think are missing or require further exploration.

Currently the focus of vehicle emissions is that emitted during the in-use phase from the vehicle’s tailpipe. When a vehicle is fossil-fuelled, carbon that has been stored underground for millions of years is released into the atmosphere as CO2 and is effectively extra or additional carbon. With sustainable fuels, the CO2 released at the tailpipe has, instead, come from recycled carbon that has been captured by photosynthesis or directly. This “tank to wheel” approach (TTW) is heavily publicised and reported, and can influence ownership costs including VED and BIK and vehicle manufacturers compliance with CO2 fleet regulations, affecting model offerings in the UK market.

For many low carbon fuels that may likely be used in a blend or as a drop-in, their properties are either aligned or similar to the fossil fuel being substituted, and in that case produce similar levels of CO2. Without recognition of well-to-tank (WTT) CO2 savings (through the recycling of the carbon), the advantage and opportunity of low carbon fuels in this context is being overlooked and dismissed.

Policies hence should adapt to include the WTT and source of the fuel components used.

Additionally, due to the nature of sustainable drop-in replacements, they can be variably blended with fossil-based components and so there must be mechanisms in place to track the provenance (such as the Zemo Partnership’s Renewable Fuel Assurance Scheme) and validate/reward the use of these low carbon fuels. Such an approach needs to be applied to all potential energy vectors, including hydrogen and electricity, so that the in-use carbon emissions with consideration of fuel carbon intensity and grid carbon intensity are also be included, to ensure different technologies are compared equally. READ MORE

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