Therefore, it is recommended that the approach to address co-products
should be flexible and, that the most appropriate approach (i.e. that
which most accurately estimates the net GHG impact) should be
decided for each individual co-product. In practice, this is means that:
• Substitution will be the first choice approach, and
• (I think they omitted the word energy here) Allocation will be preferred when co-products are used for heat or
electricity generation or are converted into another biofuel.
• Allocation by market value will be allowed when it is not possible to define
a sensible substitution approach.
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By substitution they mean that one should measure what the marginal quantity of the co-product replaces (i.e. DDGs might replace soy meal so the substitution method would credit corn ethanol with the carbon footprint of making the amount of soy meal it replaces in animal feed. They recommend that this is would be allocated by protein equivalence).
1 comment:
The version of the RTFO Carbon Reporting Methodology you are referring to is out of date. This was a version consulted on in the middle of last year and has since been updated.
In particular, the co-product treatment procedures were updated. The recommendation to use allocation by energy content for energy co-products was withdrawn. During the consultation exercise many stakeholders highlighted the fact that use of the energy allocation method could lead to perverse incentives (e.g. little or no reward for installing an efficient CHP system at a biofuel plant, which would have significant GHG savings).
Energy coproducts are now treated by system expansion / substitution. The rest of your post is accurate.
Please see the following link for the final version of the Carbon Reporting Methodology: http://www.dft.gov.uk/rfa/_db/_documents/080227_Final_Carbon_Reporting_Methodology.pdf
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