Safeguard Mechanism - Best Practice Emissions Intensities Update
14 June 2024
BioLPG and rLPG (or renewable propane and butane) are 'drop in' replacement fuels for regular LPG, which are critical in supporting industries across Australia to decarbonise.
With reference to Item 23 – Renewable Aviation Kerosene (RAK) – GEA notes that RAK is synonymous with Sustainable Aviation Fuel (SAF) as an emerging decarbonisation fuel in Australia.
GEA seeks the inclusion of other future Low Carbon Liquid Fuels (LCLFs). In the process of producing Renewable Diesel and Renewable Aviation Kerosene, bioLPG will be produced. Industry is also developing and researching technologies alternative processes to produce renewable LPG (rLPG), also known as bioLPG, and Renewable Dimethyl Ether (rDME).
These technology pathways would produce significantly different emission intensities for the production facility, and we, therefore, recommend:
1. The inclusion of bioLPG emission intensity alongside RAK and RD when produced at a HVO facility.
2. A separate emission intensity for a bioLPG production facility when it is made on purpose through alternative processes like:
- Gasification and Fischer-Tropsch
- Gasification and methanation
- Oligomerisation
- Digestion
- Pyrolysis
- Fermentation
- Power-to-X
Both rLPG and rDME can be sustainably produced either as the primary product or as by-products of other sustainable biofuel production processes, such as SAF. In summary we recommend the facility emission intensity be separated into the production technology groups.
GEA emphasises that bioLPG and rLPG are not greenhouse gases and are not susceptible to fugitive emissions due to their containerized transport and usage. These renewable products provide sustainable fuel options for hard to abate sectors, such as commercial, industrial (including agriculture), food processing, infrastructure projects, industrial sites and recreational settings (BBBs, caravans, outdoor heating, etc), while ensuring reliable, secure and affordable energy supply.
GEA highlights that these LPG alternatives offer a more efficient and less environmentally impactful fuel source compared to diesel generators, with superior emissions profiles even to renewably produced biodiesel.
The use and recognition of bioLPG and rLPG products, as well as rDME, enhance the economic case for all SAF production by expanding the range of sustainable fuels that can be derived from biomass sources. These renewable fuel products are complementary to RAK and RD, contributing to a more diverse and sustainable energy landscape.
In assessing current and future gas supply and demand, GEA seeks to inform the Safeguard Mechanism consultation on the opportunities for bioLPG, rLPG and rDME to be used across residential, commercial and industrial (including agricultural) purposes, with an 'actual zero' emission profile – all via a reliable, domestically-produced energy source that takes pressure off an increasingly overburdened electricity grid.
In addition, through the export potential of bioLPG, rLPG and rDME, the production of these renewable gases can assist Australia's trading partners in meeting their net zero targets. LPG's unique opportunities to decarbonise should be seized upon as complementary to government policy and goals.
[ENDS]
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