National Greenhouse and Energy Reporting System (NGERS)
24 May 2024
GEA fully supports the market-based approach for Sustainable Aviation Fuel (SAF), including Renewable Aviation Kerosene (RAK) and Renewable Diesel (RD).
Additionally, we would like to recognise all biofuels, including renewable propane and butane, that will be produced in the manufacturing of RAK and RD.
These are 'drop in' replacement fuels that are critical in supporting industries across Australia to decarbonise.
Furthermore, GEA highlights the significance of acknowledging other sustainable renewable fuels that can be produced concurrently or utilised as by-products in the RAK and RD production processes.
The recognition of by-products of SAF is crucial, especially in light of the current initiatives by the Australian Renewable Energy Agency and the Sustainable Aviation Fuel funding initiative.
Net zero bioLPG will be available in Australia as early as 2025-26 as a by-product of biodiesel and SAF production using the hydrotreated vegetable oil process. Therefore, GEA seeks acknowledgment in the National Greenhouse and Energy Reporting System (NGERS) for all relevant and appropriate renewable SAF fuels from equivalent sources, including bioLPG.
BioLPG and, ultimately, rLPG, are identical molecular compositions to conventional LPG and can currently be extracted from bio/renewable origin, including during RAK and RD production. This existing, sustainable, renewable rLPG technology is already in international use (as evidenced by the UN international transport standards amendment to UN 1075 (liquefied petroleum gases) to include LPG produced from bio sources for transportation.
Additionally, GEA also advocates for the recognition of renewable liquid fuels that are 'drop in' additives, serving as a blend and renewable fuel supplements, consistent with the proposed NGERS amendments. An example is renewable Dimethyl Ether (rDME) – a renewable liquid fuel already in international use, which can supplement conventional LPG or bioLPG.
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 NGERS 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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