Aggregate Industries’ answer to the 2.5 million mile haulage scheme for its Straitgate Farm planning application is to claim that the HGVs hauling as-dug sand and gravel to Uffculme for processing would run on chip fat biofuel, or HVO as it's commonly known – hydrotreated vegetable oil.
How this would be done is anybody’s guess, since the company does not own its own fleet of trucks and HVO is not available on garage forecourts – as Devon County Council pointed out. How this would be monitored and policed is another issue – as the Council also acknowledged. HVO was part of the S106 heads of terms when the application was originally determined, part of the legally enforceable planning obligations; now the HVO proposal finds itself as another planning condition – and we know the problems with enforcing those.
Devon County Council’s barrister said in his closing submission:
206. The Appellant’s proffered obligation/suggested condition (it is difficult to keep track – it was in the draft s.106 but seemingly no longer) that the vehicles use HVO goes nowhere. Mr Gould gave up that he can point to no example of the use of HVO in the aggregates setting. This is, as was put to him, innovative technology (he denied that, before being taken to his Proof as “innovative” is his own word). There can be no reliance placed upon it. Nor has there been any evidence from the Appellant as to how the MPA might hope to monitor so as to ensure HVO is being used. The Appellant’s suggested condition does not begin to answer matters: it simply seeks to kick the can down the road and require the question of whether monitoring is possible to be addressed later. Not good enough. To be addressed now.
Mr Gould, who represented Aggregate Industries, preposterously claimed "the proposal minimises transport of minerals with innovative solutions to help achieve this".
Apart from all that, uptake of HVO is being rejected by a number of organisations, including the Environment Agency and others:
Environment Agency blocks HVO https://t.co/y0qaUxzBwU #constructionnews #construction #businessnews pic.twitter.com/78cErRoej8
— Construction Index (@TCIndex) September 20, 2022
Bursting the HVO bubble https://t.co/H2apUzJwOZ #constructionnews #construction #businessnews pic.twitter.com/cdKRx1Lu9Z
— Construction Index (@TCIndex) November 15, 2022
Even before determination last year, we pointed to the fact that rising imports of used cooking oil into the UK for biodiesel is indirectly "encouraging more deforestation in Southeast Asia" with some research claiming it’s "three times worse for the climate than regular diesel when indirect emissions from changes in the use of land are accounted for".
Others have problems with it too. HVO is primarily made from used cooking oils or UCO:
According to Jo Gilroy, Balfour Beatty’s group sustainability director, it is simply a matter of due diligence. “We’re very good at jumping on solutions and thinking they’re the answer to our problems, aren’t we?” she says. “We look for easy wins, and HVO looked like that.
“But any one-hit wonder solution needs to be examined carefully; you always have to do your due diligence.”
As momentum built in favour of HVO, Balfour Beatty decided it had to delve deeper into the sustainability claims being made for the fuel before approving its use. And what it has found so far has only raised doubts.
The chemistry of HVO is well understood but less clear is the sustainability of its supply chain. “What does the supply chain look like?” demands Gilroy, “Nobody knows - it’s very complex and there’s very little transparency.”
One of the big attractions of HVO is that it purports to transform a troublesome waste material into a valuable commodity. But Gilroy says this is misleading: “UCO has always been used in the production of animal feed – it’s not a waste product,” she says.
This might appear to be a mere technicality, but if one industry’s feedstock is diverted to supply another industry’s needs, alternative sources must be found. If producers of animal feed cannot obtain enough raw material in the form of UCO, they will turn to primary sources, namely commercially-grown vegetable oils such as palm oil.
Mention palm oil and you open a whole new environmental can of worms...
Balfour Beatty’s Position paper on HVO can be found here:
There is a high risk that the resulting increase in demand for used cooking oil is causing deforestation and the draining of peatland and marshland in countries such as Malaysia and Indonesia where farmers are having to grow palm oil to produce animal feedstock. Such displacement activity has an extremely damaging impact on the environment: these areas store large amounts of carbon, so clearing them would lead to a significant increase in carbon emissions in those countries. EU research indicates that once the effects of land use change and draining of peatland are accounted for, the GHG impact of palm-oil derived HVO could be up to 3 times greater than standard fossil fuel diesel.
