CASE FOR THE REDUCTION OF FUEL TAX ON BIOFUELS
It is proposed to HM Government that the rate of Fuel Tax applied to biodiesel should be reduced to 20p per litre when used as an Alternative Fuel, or zero rated when used as a Fuel Additive, subject to a limit of 10%. (August 2000)
Following the oil crisis of 1973, world attention turned to sustainable biofuel sources which would relieve dependence on petrofuels and provide at least a measure of fuel security. One of the foremost countries to follow this path was Brazil. Despite being turned down by the World Bank for finance, considerable effort was put into the production of ethyl alcohol (ethanol) from sugar cane with the result that, twenty five years on, Brazil is now producing 45% of its own ecologically sustainable transport fuel. This amounts to some 12bn litres - 10 million tonnes - of alcohol per annum.
Similarly, Austrian and then German industry later took the initiative using a climatically suitable crop - oilseed rape - the latter setting up, in 1991, a pilot biodiesel plant able to produce 350 tonnes per annum. This was increased in 1992 to 8,000 tonnes and subsequently, with financial assistance from DGXVII of the EEC, a DM20m (£7m) 80,000 tonne plant was commissioned in 1994. Production target for 2000 is 416,000 tonnes, in support of the EEC Agenda 2000 target of a 5% market share for biofuels by the year 2005 and 12% by 2010. Italy is producing 125,000 tonnes of biodiesel per annum, used mainly in feeding central heating boilers.
Large scale biofuels development in the USA started with ethanol, the 4.4bn litres production (1999) per annum providing an estimated 200,000 jobs in the agricultural and rural sectors. Biodiesel production was spearheaded by the Soybean Growers Association, spurred on by a glut of soy oil. Production for the year 2000 is estimated at over 2m tonnes. - double that of total European production.
Meanwhile, apart from an ineffectual attempt in 1995, the UK biofuels industry has been actively discouraged by excessive taxation.
Use of transport fuels in the UK is governed by the 1979 Hydrocarbons Act, which refers only to "mineral oils". In order to comply with EEC Directive 92/81 (Article 2.3 - "any product intended for use, offered for sale or used as motor fuel, or as an additive or extender in motor fuels, shall be taxed as motor fuel."), HM Treasury widened the scope of the Finance Act 1993 (Section 10) to "mineral fuel substitutes", which was applied by HM Customs & Excise on 1 December 1995 under S.I. 1995 No 2716.
(Directive 92/81 also states - "Whereas, however, it is appropriate to permit member states to apply an optional basis certain other exemptions or reduced rates within their own territory where this does not give rise to distortions of competition ... (and) ... in the field of pilot projects ... in particular in relation to fuels from renewable resources." This has been disregarded.)
This EEC measure had the effect of applying the same fuel tax to sustainable biofuels as that applied to fossilised petroleum fuels. Germany, France, Italy, Belgium, Austria, Sweden and Norway have taken advantage of subsequent EEC legislation which permitted a "pilot quantity" of 5 million tonnes of oil equivalent to be produced by reducing tax on biofuels.
The UK has not.
Subsequent to this legislation, EEC Directive 99/880 was published on 17 December 1999 and allowed member states to "introduce exemptions or reductions in the excise duty charged on mineral oils (which 92/81 has deemed to include vegetable oils) for special policy considerations." Under Article 1.15, the UK has dispensation until 31 December 2000 to reduce the taxation on "waste oils (unspecified) which are used as fuel, either directly after recovery or following a recycling process for waste oils, and where the reuse is subject to duty." This, it appears, could apply to the use of recovered vegetable oil in producing biodiesel, which would spark off an immediate response from industry were it to be enshrined in UK legislation.
The way is therefore legally open for UK legislation to allow for the production of sustainable transport fuels.
Given the will.
UK SUSTAINABLE ENERGY POLICY
There is no sense of urgency within the UK government to establish energy security, despite the assurance of oil supplies being finite. However, there are environmental obligations brought about by global treaty, to which successive UK governments have been signatories.
Advised by the Energy Technology Support Unit (ETSU), the Department of Trade and Industry has devoted most of its available efforts and budget to the fostering of electricity generation under the Non Fossil Fuel Obligation (NFFO) series of initiatives. This has favoured short rotation coppiced willow and, more recently, miscanthus grass as biomass sources, together with wind power and small hydro-electric schemes.
No account has been taken of the fact that battery-powered electric vehicles are not yet sufficiently developed as viable transport (www.dewinne.freeserve.co.uk/electric.htm), nor of the difficulty of running road, sea or air transport vehicles on willow or miscanthus.
The long term transport energy - and therefore economic - security of the UK is being put at risk.
UK SUSTAINABLE TRANSPORT FUELS POLICY
The UK government has no sustainable transport fuels policy.
UK CLEANER TRANSPORT FUELS POLICY
In the 1999 UK Budget, the Fuel Tax on Ultra Low Sulphur Diesel was reduced by 3p per litre to "encourage the use of more environmentally friendly transport fuels". In the 2000 Budget, the Fuel Tax on Ultra Low Sulphur Petrol was set at 1p below that of unleaded petrol. The tax rate for LPG, LNG and other gas fuels is set at 15p per kg, on the grounds that there are less noxious emissions from these fuels and also that they contain less energy than liquid fossil fuels. There is no Cleaner Fuels Task Force (equivalent to the Cleaner Vehicles Task Force) within the DETR to advise otherwise. As a result, biodiesel has been penalised by the higher rate of petrodiesel fuel tax, despite the considerable environmental benefits of the fuel and EEC dispensations.
"The environment - are you doing your bit?" has a hollow ring to it.
THE NEED FOR LIQUID BIOFUELS
It is now accepted - even by oil companies - that the world oil supply is running out. The current estimate is 60 years supply at the present rate of consumption or, at the projected increase of just 2% per annum by developing economies, 40 years. This is just one generation away, after which oil shale and other sources will prove economically disastrous. Of course, OPEC and the non-aligned oil producers will not let this happen, and their application of economic forces will ensure that their income is maintained.
However, the inevitable effect will be more swingeing price rises in the cost of oil than has been seen since the low level of 1998. Within the last two years alone, the price of crude oil has trebled and only been forced down by American influence in the Middle East and OPEC agreement to increase production by half a million barrels a day.
The equation is simple - lack of oil equals lack of transport which equals substantially reduced economic activity.
The damaging economic, sociological and political implications of inevitable future developments are deserving of considerably more thought within both business and government circles. UK long term energy security is far from being established. The oil remaining in the North Sea should be used as the source of finance to develop maximum sustainable energy resources.
TRANSPORT BIOFUELS OPTIONS
The viability of transport depends on the portability of the energy source for motivation. Not included, of course, are electric trains and trolleybuses which have their energy carried to them by power lines. Hence, the storage density of energy becomes the most important factor. (This is why hydrogen - the perfect fuel - is not yet practical as a transport fuel.) Liquid biofuels are readily available sources of concentrated energy. The three most viable fuels are methyl alcohol (methanol), which contains one third of the energy of petroleum fuels, ethyl alcohol (ethanol) half and biodiesel 90%. Of these, biodiesel is also the most economical to produce. It is totally compatible with existing vehicle engines and commercial fuel distribution systems.
See - www.biofuels.fsnet.co.uk/sustain.htm
The most important factor of all, though, is the proven worth of these biofuels which exists, unlike the future promises of fuel cells, hydrogen power sources and electric vehicles - all of which are in need of further development before they become practical. Tests and trials have been carried out on all aspects of the production and use of biodiesel - esterification, energy content, life cycle, emissions, emission control, lubricity, biodegradability, toxicity and - most important of all - carcinogenicity.
On 22 June, 2000, biodiesel was finally approved by the US Congress, having passed all the Environmental Protection Agency trials.
Biodiesel is nothing new - it has been known since the beginning of the last century, but has been neglected due to the availability of cheap petroleum fuels. It is a benign substance, being made from any number of plant oils (rape, hemp, sunflower, soy, palm and algae to name but a few) fish oils and animal fats, grease and tallow. It is less toxic than common table salt and rapidly biodegradable. It travels safely.
It contributes virtually zero carbon dioxide emission to the atmosphere. The plants, having absorbed the CO2 whilst growing, therefore act as an annual carbon sink.
It is made through a process of esterification, involving reaction with an alcohol in the presence of a catalyst. The ester product varies by name (RME - rape methyl ester; HEE - hemp ethyl ester, etc) but very little by nature - carbon plus hydrogen plus oxygen. Due to the oxygen content it is a very clean fuel, producing 50% less carbon particulates than petrodiesel, together with less nitrogen and carbon monoxides.
The particulate matter emitted by biodiesel is not carcinogenic, unlike that of petrodiesel. Biodiesel contains no sulphur, other than by contamination from the soil, acid rain or commercial alcohol used in the processing.
The by-product from the manufacturing process - glycerol - may be used to produce an estimated 3500 commodities, including glycerine, food and petroleum machinery lubricants, sweeteners, skin conditioners, tocopherols (vitamin E), moisturisers, fertilisers and many products used in food preparation. Glycerol also contains almost 20% of the pre-absorbed carbon, thereby achieving longer term sequestration.
Biodiesel is a highly efficient lubricant - a 5% additive being used by three major French oil companies to compensate for the lack of lubricity of ultra low sulphur petrodiesel fuel.
Biodiesel is produced in Europe under the accepted standard of the Austrian Biofuels Institute specification E DIN 51606 and, in the USA, under National Renewable Energy Laboratories specification B100. It may be mixed with petrodiesel in any ratio and improves tailpipe emissions - the USA favouring a 20/80 bio/petrodiesel ratio.
In terms of life cycle energy analysis, biodiesel takes approximately the same amount of energy to produce as petrodiesel - 15%. Of this energy requirement, two thirds is consumed by agricultural machinery which, of course, can run on sustainable biodiesel.
One added environmental benefit not mentioned in any other literature researched is the contribution made by the growing plants to the oxygen content in the air, through photosynthesis.
Much of the foregoing information is contrary to current understanding in UK government circles - in particular, the Departments of Trade and Industry, the Environment, Transport and the Regions and Agriculture, Fisheries and Food.
The reason for this is deplorable.
THE MISINFORMATION SURROUNDING BIODIESEL IN THE UK
In 1996, the Energy Technology Support Unit (ETSU) based at AEA Harwell produced a report for the Department for Trade and Industry (DTI) entitled "Alternative Road Transport Fuels - A Preliminary Life-cycle Study for the UK." (The primary omission was on the part of the DTI, by forgetting that alternative and sustainable fuels will also be needed for sea and air transport when oil supplies dwindle.)
The staggering conclusion of this ETSU report was that the UK production of biodiesel was not worth-while, due to their finding that carbon dioxide emissions savings were only 60%! This low figure became the basis for UK government departmental thinking thereafter and the prevailing attitude that biodiesel was not worth pursuing as a viable source of renewable energy.
Efforts by the DTI to reduce greenhouse gas emissions therefore became fixated on the production of electricity via the Non Fossil Fuel Obligation (NFFO) schemes. This has negated any possibility of developing a sustainable transport fuel policy in the UK. The subject has simply been ignored.
In 1999, the British Association for Bio Fuels and Oils (BABFO) - a voluntary pressure group formed to campaign for a British biofuels industry - managed to acquire some funding from the Altener II programme and, with this, commissioned the reputable company ECOTEC Research and Consulting Ltd to carry out desk research on the ETSU findings. ("Financial and Environmental Impact of Biodiesel as an Alternative to Fossil Diesel in the UK") (ECOTEC has also carried out commissions for DTI.)
What they found was a series of errors which should not be accepted from supposedly competent and highly paid consultants to the British government without protest.
The root cause of there not currently being a British biofuels industry is the use of one figure used in the production energy calculation, which was exaggerated TWENTY TIMES.
The ETSU report states (page 156) that 238MJ of energy was required to crush the oil from rapeseed, energy content of which was 1GJ - that is, almost a quarter of the total energy content of the oil. This figure didn't seem credible, so ECOTEC referred to the source quoted (Culshaw and Butler, 1992) only to find that there was no mention of this subject in the text. ECOTEC went to ETSU and asked to interview the authors of the life-cycle report, only to be told that the individuals no longer worked there. Concerned to arrive at the correct figure, ECOTEC approached Cargill plc, the biggest oilseed crushers in the UK. The figure obtained from the company was 5% of that used in the ETSU report to calculate the life-cycle of biodiesel.
This error on the part of ETSU employees resulted in the low carbon dioxide savings finding (the 60% figure), and also significantly exaggerated all other noxious emissions figures. Not content with this, the error was further compounded by -
(1) a miscalculation of the energy required to grow rape on set-aside land (forgetting that even set-aside land has to be looked after),
(2) omission from life-cycle calculations of the energy content of the valuable by-products, straw and pressed oilseed cake,
(3) disregard of the fact that biodiesel could be used to power the tractors and machinery used to produce the crop, thereby incurring significant emissions savings, and
(4) the inclusion of high sulphur emissions, due to the energy miscalculations.
The vehicle particulate emissions findings were based on half-a-dozen half-hearted and very unscientific trials carried out in the UK during 1995ish - partly with assistance from a reporter from the periodical "Commercial Vehicle". Not surprisingly, these were highly subjective, inconclusive and totally inaccurate, but helped the misinformation along the line.
Not mentioned in the ETSU report was the significant factor that petrodiesel exhaust particulates (PM10) contain carcinogenic polyaromatic hydrocarbons. Biodiesel particulates do not. Disregarded also was one beneficial effect of manufacturing biodiesel from the oil, from which the by-product is carbon-retaining liquid glycerol. This acts as an environmental buffer.
The result of this compendium of errors has been the misleading for five years of the DTI, the DETR and the various government ministers attached thereto, together with the Chancellor of the Exchequer and HM Treasury, all of whom have accepted the flawed ETSU report without question despite the existence of vast amounts of information to the contrary and the continual lobbying of environmentalists.
ETSU, DETR and DTI were informed by BABFO of the ECOTEC report in early 2000. No action has been taken by ETSU to review or rescind the report for which they were responsible, despite the damaging commercial effects it has had. Similarly, no action has been taken by DTI to call ETSU to task, or to ask for their (our!) money back.
Despite a meeting being held between Lord Whitty, Minister responsible for the DETR, and the chairman of BABFO, DETR has failed to respond to the information - indeed, six weeks after the meeting, Lord Whitty wrote a letter to a fellow MP, stating that - "(Biodiesel) may also contribute less than fossil fuels ... to net emissions of carbon dioxide ... but ... the production and processing of the crop can be quite an energy-intensive process.
"Furthermore, in practical terms the UK is not well suited to the production of biofuels because of the comparatively small area of land available for the cultivation of the feedstock crops such as rapeseed from which the fuels are derived. This will always limit the amount of fuel which is available to the market."
This latter view, stated by Lord Whitty on the basis of information given him by his department, is not compatible with the attitude shown by that same department towards small-scale hydro-electric generation plants. In terms of scale, projects as small as 30kW capacity (Park Mills, Antrim) have received financial incentives under the NFFO scheme.
This is the energy equivalent of producing 30 tonnes of biodiesel a year - less than 100 litres a day.
Is it better to create 10,000 new jobs, or none at all?
FRUSTRATION OF GOVERNMENT COMMITMENTS
Due to this compendium of errors and dog-in-the-manger attitude on the part of both the DTI and the DETR, the legally binding pledges made by the UK government at the Rio and Kyoto conferences have been frustrated to a quantifiable degree.
In 1996, there were some 506,000 hectares of land in the UK on set-aside grants. (MAFF does not appear to have taken the trouble to update the statistics given on its web site, despite an hour spent searching what must be one of the clumsiest sites on the web - www.maff.gov.uk)
In round-figure terms, every hectare suitable for the growth of oilseed rape produces one tonne of biodiesel, which replaces one tonne of petrodiesel, thereby reducing carbon dioxide emissions by 3.7 tonnes - that is, one tonne of carbon emissions saved towards the objectives.
Had British industry been encouraged by a reduction in fuel tax in 1995, based on the examples set in Austria, Germany and France, biodiesel production would now be in the region of 200,000 tonnes per annum and achieving a saving of 200,000 tonnes of carbon emissions.
This is 8% of the 2010 carbon saving target set by the government (Budget 2000) for the Climate Change Levy and, incidentally, 40% of reductions anticipated due to company car tax reform - and far simpler, administratively!
In addition, half the estimated particulate reduction that the ULSD fuel duty differential would have been achieved.
Cost to the Exchequer (at the proposed reduced rate of 20p per litre) would have been £56m - offset by the taxed income of the people employed in the additional jobs created.
This is less than half the cost of reducing vehicle excise duty by £55 on 2 million cars of under 1100cc as the Chancellor did in 1999, but with an immediate and quantifiable effect.
AGRICULTURAL JOB CREATION
Surprisingly little attention has been paid to quantifying the social and economic effects of growing biofuels. Even the BEAM project undertaken by the University of Wales omits this very positive and beneficial aspect. (This is the only known feasibility study on the production of biodiesel carried out in the UK - http://www.bangor.ac.uk/~afs117/biod.htm ) DTI takes a stab at it by guessing 16 jobs per £1m capital expenditure. Irish (Lalor) studies are a little more helpful at 1 job per 20 hectares brought back under cultivation.
German output of oilseed rape in 1995 (Schope, 1996) was estimated at 300,000 hectares, creating 5,000 new jobs in the agricultural sector, but production and distribution of the biodiesel was not included. This justified 70% of the tax concessions given by the German government. The French have turned over 70% of their set-aside land to biofuel crops and created 27,000 new agricultural jobs.
The UK has been deprived of a job creation activity by a bungle.
Some EEC references -
International Energy Agency -www.oecd.org/env/trans/grphpage/surv8.htm
EU Atlas programme - http://europa.eu.int/en/comm/dg17/atlas/html/body_biodmarfutc.html
EU Zeus programme - www.zeus-europe.org/fuels.html
Various other relevant EEC papers may be accessed via - www.biodiesel.at/references.html
EEC WHITE PAPER - TAX RATE RELIEF
On 26 November 1997, as part of the Agenda 2000 programme, the European Commission published a White Paper concerning Biomass. It set out a strategy for the increase in sustainable energy contribution from 6% to 12% by 2010 "without excessive financial burdens". This new bioenergy initiative stated that -
"at present, the market share of liquid biofuels is at 0.3%, including all alcohols, ETBE and biodiesel esters. Given the fact that the production cost of liquid biofuels is three times that of conventional fuels, an increased use can only be achieved by a tax rate relief and subsidised raw material production. The Commission proposes that a market share of 2%, corresponding to about 5Mtoe (million tonnes of oil equivalent), could still be considered as a pilot phase, thus allowing a detaxation within the framework of the Directive 92/81.
"After realising this pilot phase, the objective of 7.5% market share (18Mtoe) should be attained ....... involving the use of 3.7Mha of agricultural land. Thus, the White Paper proposes for biomass a forty to sixty fold increase to the liquid biofuels production."
In 1999, more than a million tonnes of biodiesel was produced in Europe, with targets to double this by 2001. The limit will have been reached before the end of 2002, leaving the UK with little chance of developing an effective biodiesel industry.
The current EEC Altener paper on removing non-technical barriers to the development of liquid biofuels may be found on -
RECTIFICATION OF THE ERRORS
DEPARTMENT OF TRADE AND INDUSTRY
The responsibility for accepting and tolerating the errors must lie with the DTI. Wrongly advised by ETSU and having a Renewable Energy Advisory Committee (REAC - which, with incredible naivety, lacks an agricultural representative and has recently lost even the representative from the National Energy Action charity) the constant rejection of approaches to have the information re-examined has been irresponsible, to say the least. A day spent surfing the Internet is all that is needed to verify the information needed to rectify this damaging situation.
It is therefore proposed that the DTI re-structure the REAC, installing people with practical experience of renewables rather than theorists, and then listen to their advice.
The EEC has permitted the reduction of tax on biofuels by member states, but has put a cap of 5m tonnes on the amount of fuel able to be produced as a pilot scheme. This dispensation, due to the pro-active stance of particularly the Germans and French, will be exhausted by the end of 2002. Time is therefore of the essence.
The gestation period of a complex industrial plant manufacturing biodiesel from raw oil is at least two years, given the capital requirement for the plant, planning permissions, design and manufacture of the plant equipment and the setting up of administration and marketing functions. When completed, the cost of producing the biodiesel will be affected by raw oil and alcohol costs and the business overheads.
Invaluable feasibility investigation has been carried out by the University of Wales, at the behest of the Welsh Development Authority, their BEAM project determining the viability of producing the fuel. Their conclusion was that, in 1995, the cost of producing biodiesel would result in a selling price of at least 27p per litre, given that all the by-products were saleable, rising to 37p per litre if not. It also concurs with the 1999 production cost given by Oelmuhle Leer Connemann of 17p per litre (exclusive of oil feedstock) which is the current price of petrodiesel, exclusive of tax.
This renders biodiesel unacceptably higher in price than petrodiesel.
The current cost of building a stand-alone biodiesel plant for the production of 300 tonnes per annum is estimated at £400,000; for 8,000 tonnes per annum, £800,000, and 100,000 tonnes per annum, £8m. (Oelmuhle Leer Connemann, August 1999) More economical would be the setting up of plant manufacturing biodiesel from recovered vegetable oils and animal fats, utilising existing facilities and business structures.
Fuel tax on biodiesel has been set by HM Customs & Excise at 48.82p per litre, the same as for ultra low sulphur petrodiesel (ULSD). This is, firstly, an unfairly inflated rate of taxation by virtue of the reduced energy content of biodiesel.
Biodiesel is an oxygenated fuel and contains around 10% less energy content than its fossil counterpart. Therefore, the tax should logically be reduced to 90% of that applied to the ULSD rate of 48.82p - viz., 43.94p per litre. This precedent has been set by the rates applied to the lower energy gas fuels - all of which are derived from fossil sources - ULSD, and ultra low sulphur petrol.
As matters stand, if biodiesel was able to be produced at the gate price of 37p per litre, this would set a pump price of 37 + 48.82 + 15.02p VAT = £1.084p per litre. This is clearly unacceptable, being 20p above the pump price of petrodiesel. In order to provide sufficient an incentive for producers to invest in the capital plant, given such a short-term advantage, it would require a gate price of at least 47p.
For a marketing advantage to be given to British producers, the fuel tax would have to be reduced to 20p to give a pump price of 78.7p per litre (47 + 20 + 11.7p VAT) - marginally below that of petrodiesel. This requires a tax reduction of 28.8p per litre. (In Germany, the pump price of petrodiesel is generally DM1.55 (52p). Biodiesel is available at over 600 filling stations and is sold at DM1.45 (48p)).
As the price of petrofuels increases, so does the commercial viability of natural fuels. The tax concession would therefore be able to be reduced progressively in parallel.
GRADUATED VEHICLE EXCISE DUTY (w.e.f. 1 March, 2001)
There is an anomaly created by this poorly constructed system, whereby a car with a nominally high rate of carbon dioxide emissions is taxed at a higher rate. However, this same car is able to run on biodiesel, which is a "cleaner fuel" and causes virtually zero carbon dioxide emissions. Only by offering the biodiesel to the motorist at a reduced price can this situation be remedied.
In order to produce biodiesel from rapeseed oil, it is first necessary to grow the crop. This introduces a substantial time-lag or, alternatively, importation of raw materials.
If notification of a reduced rate of fuel tax were to be given in November 2000 for activation in April 2001, it may be possible for British industry to produce up to 2,000 tonnes of biodiesel by the end of 2001. This would cause a loss of revenue to HM Treasury (at the proposed reduced fuel tax rate of 20p per litre) of some £600,000 but also mean the creation of a completely new British industry involving new employment and the income accruing from this.
If 8,000 tonnes per annum were able to be produced by the end of 2002, this would cost HM Treasury some £2.5m in lost revenue.
It would also effect a saving of 8,000 tonnes of carbon emissions.
In addition to raw oils, biodiesel may be made from recovered vegetable oil (RVO) from food factories, restaurants and take-away establishments, even though they may be mixed with animal fats. At present, much of this is heat treated and then injected into the human food chain by being used to supplement cattle fodder. This process can allow cross-contamination by e-coli and other organisms, and also contamination by other matter whilst awaiting collection. This is of serious concern to EEC health authorities.
The value of the treated RVO is lower than the cost of new oil, although the cost of producing the biodiesel is raised by the necessity for analysis before reacting and more complex processing. The resultant biodiesel is equal in quality to and has the same carbon saving effect as that produced from fresh oil. It is also possible to produce biodiesel from tallow (as in the USA) and waste fats from the meat processing industry. There is a current surplus of this material in the UK. The plant required for this is less complex than that required for the more efficient continuous process used for raw oils, but is more labour intensive.
PLAN OF ACTION
No further studies, tests, research, development or trials are required, so should not even be considered. To do so would be a total waste of public funds. Despite the government's "joined up" policy, there is little evidence of liaison between departments. Vertical chains of command have been maintained, requiring convoluted systems of communication. Sources of funding are many and varied, and a nightmare of digging for the right purse.
In addition to the restructuring of the REAC, it is therefore proposed that an independent British Biofuels Board should be set up, substantially financed from the public purse. It should comprise a cross-curriculum body, involving existing manufacturers of biofuels for their practical experience. It should be tasked with ensuring compliance with EEC objectives to achieve biofuels targets by the given dates. It should be a pro-active organisation, not a passive sponge. It should have the responsibility for investigating any new source of biofuels energy, including new strains of feedstock. Consultations should be held with biodiesel producers and potential producers. Together with representatives of the fossil oil industry, it should determine the potential for the French approach - that is, the introduction of a biodiesel lubricity and emissions improving additive. This would provide the production incentive of an immediate UK market.
POTENTIAL LEGAL IMPLICATIONS
The International Convention on Human Rights becomes law in the UK in October, 2000. It could be argued that, by failing to take reasonable measures to ensure the availability of non-carcinogenic transport fuels, despite EEC encouragement and provisions having been made to accommodate this, the government has caused, to innocent members of the public, needless and excessive exposure to harmful emissions.
Whilst this may seem preposterous, a parallel may be drawn with anti-smoking measures taken by the government - the provision of health warnings on cigarette packets, health service advertising campaigns, anti-advertising legislation, high taxation level, etc. The choice not to smoke cigarettes or not to frequent smoking areas exists - but there is no choice but to walk along pavements skirting traffic-laden roads and to breathe the polluted air. In addition, there is the legal requirement brought about by the Maastricht Treaty and the more recent Treaty of Amsterdam for the government to take account of environmental protection requirements - which it has demonstrably failed to do in the case of biofuels.
Terry de Winne
Biofuels Northern Ireland (email@example.com)
14 August 2000