Liquid Gas UK is the trade association for the Liquefied Petroleum Gas (LPG) and biopropane (bioLPG) industry in the UK, representing companies who are LPG producers, distributors, equipment and service providers, and vehicle convertors. It is dedicated to the safe and effective development of LPG. Member companies cover 99% of the total LPG distributed in the UK; and over the next 5 years, plan to invest over £600m as an industry in infrastructure, fleet and decarbonisation. In our response, we outline how LPG and bioLPG can play a key role in the future energy mix in Wales.
An introduction to LPG and bioLPG
How should the UK and Welsh Governments work together to support the development of renewable energy projects in Wales?
With the Welsh Government recently legally committing to net zero emissions by 2050 and committing to becoming a zero waste society, it is right that a key focus of both the Welsh and UK Governments should to encourage more renewable energy production in Wales. This is a two stage process: first joint support for LPG and bioLPG as being among a basket of sustainable fuels and technologies that can enable Net Zero; then joint support to bring bioLPG production to Wales.
LPG and bioLPG are readily available, well established and affordable decarbonising fuels for off-grid homes and businesses in Wales. LPG is the lowest carbon conventional energy source which provides immediate, expedient and cost-effective heat and energy for off-grid homes in Wales. LPG and BioLPG also compares very favourably to biomass on air quality.
Last year in December, the Welsh Government funded 120 homes to be heated by LPG hybrid heat pumps through its Optimised Retrofit Programme. We also commend the Welsh Government for its proposal in the recent Clean Air Strategy to develop a boiler scrappage scheme to promote conversions away from coal, (which we note should also extend to heating oil). This is a measure that off-grid consumers will understand and allow them to make carbon emissions savings with a LPG / bioLPG standalone boiler or installing a hybrid or pure electric heat pump. These are two initiatives that the UK Government should look to fund to support cleaner heating systems. In the non-domestic environment, the fuels also have the potential to replace one third of all the coal and oil currently used to heat non-domestic buildings as well as for industrial processing, saving 3.5million tones of CO2.
However, the UK and Welsh Governments need to clearly back bioLPG as a technology that can support and complement decarbonisation. Most urgently, with the UK Government’s draft off-grid regulations to be published soon, the phase out of high carbon fuels should not block fuels that can support a transition to Net Zero, such as LPG and bioLPG. The flawed EPC methodology also needs to be reformed so that off-grid homeowners aren’t unfairly penalised just because they are off the gas grid and it no longer encourages off grid users to move to high carbon fuel sources. With areas in Wales like Powys having 70% of homes off the gas grid, this unfairness will disproportionately affect Welsh rural homeowners, landlords and feeding through to renters.
Industry has been investing not only in its infrastructure as highlighted at the beginning of the response, but also specifically in bioLPG. In the last 12 months to April 2020, industry investment in bioLPG totalled more than £100 million. Support for bioLPG from across Government will help secure more investment in supply, and to be covered further below, developing UK-based production. With the right support, we could see the establishment of the indigenous production of bioLPG in Wales.
What opportunities are there for renewable energy to aid Wales post-COVID-19 economic recovery?
LPG and BioLPG can a significant part in to play helping Wales reduce its emissions and deliver a circular economy; this role is further enhanced through indigenous production of bioLPG using waste products, sustainable feedstocks both as a sole product or as a co-product of making renewable aviation or road fuels.
A recent study by NNFCC found that the deployment pathway for a full switch from fossil LPG to bioLPG by 2040 is considered feasible. NNFCC found that there is significant potential for rapid scale-up of indigenous bioLPG production in the UK, as a co-product of sustainable aviation fuel production at new HVO plants or from establishing gasification and fischer tropsch synthesis facilities.
Indeed, there is currently a strong focus on how to promote production and use cleaner aviation fuels. As bioLPG is a co-product of sustainable aviation fuel production, there should be incentives developed to direct the bioLPG into decarbonising hard-to-treat homes, businesses and industrial processes. This also ensures best use of feedstocks, with a two for the price of one mentality and enables industry to tackle the two largest emitting sectors – heat and transport.
Examples of feedstocks which will be available to support UK production of bioLPG include used cooking oil, animal fat, vegetable oil, waste, plant dry matter, sugar and starch. Both Governments should work with industry to look at what feedstocks are most available and appropriate in different parts of the country and if they can facilitate the development of production facilities which can in turn supply local / regional bioLPG demand. BioLPG production also could be established near high use demand in off-grid heat, such as clusters of industrial and commercial consumers.
These new production facilities could sit at the heart of a circular economy in Wales, utilising sustainable local feedstocks, creating jobs for the local area, contributing to economic growth and ultimately creating the energy to be used in rural homes, businesses and industries.
 UKLPG, Response to A Future Framework for Heat in Buildings (June 2018)
 WLPGA, ‘BioLPG: The Renewable Future’ (2018), Page 52
 Committee on Climate Change, Net Zero – Technical Report (2019)
 National Grid, Future Energy Scenarios, July 2020
 Savills, EPCs and the Green Homes Grant, 2020
 Opportunities to Decarbonise the Non-Domestic Off-Grid Sector with LPG and bioLPG, by Ecuity Consulting, January 2021. This recent study showed that while biomass and bioLPG boilers both emit low levels of CO2, air quality damage costs are 24 times worse when using biomass than when compared to LPG or bioLPG. Indeed, based on a lifetime modelling study if the fuels were used in a distillery, biomass would produce 250 times more Particulate Matter 2.5 and 60% more Nitrogen Oxide than bioLPG.
 Opportunities to Decarbonise the Non-Domestic Off-Grid Sector with LPG and bioLPG, by Ecuity Consulting, January 2021.
 NNFCC, Biopropane: Feedstocks, Feasibility and our Future Pathway, 2019 (p. 5)
 Hydrotreated Vegetable Oils