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Beta Analytic Inc.

(Headquarters) Beta Analytic Limited


4985 SW 74 Court London Bioscience Innovation Centre
Miami, Florida 33155 2 Royal College Street
USA London NW10NH
Tel: (1) 305-662-7760 United Kingdom
Fax: (1) 305-663-0964 Tel: (44) 207 617 7490
Email: info@betalabservices.com Fax: (44) 207 160 5350
Web Site: http://www.betalabservices.com/ Email: info@betalabservices.com

Beta Public Comment on Biodiesel, Glycerol, and the Renewables Obligation

Mr. Fletcher,

Please find below our answers to your questions for the biodiesel, glycerol and renewables
obligation consultation.

Chapter 1, Question 1: Chapter 1 summarises the most frequently used manufacture process for
Biodiesel. Are you aware of any techniques used, available or foresee in the near future that
should be taken into account?

We are not aware of any future techniques that need to be taken into account.

Chapter 1, Question 2: Can any further evidence be provided to show that the source of the
transferred hydrogen atoms within the glycerol cannot come from the methane used in the
manufacture of the methanol?

We believe that this would not be possible. On the other hand, we believe that radiocarbon dating
can be used to determine whether the glycerol is derived from fossil fuels, such as methanol
made from fossil fuel methane.

By analyzing the carbon atoms with radiocarbon dating of both the biodiesel and the glycerol
produced in the manufacturing process, one can easily determine whether glycerol might be
coming from fossil fuel derived methane.

Radiocarbon dating is regularly used to determine the biomass percentage of biofuels such as
biodiesel. Consequently, there is no reason why this method cannot be used to address whether
glycerol is made from fossil fuel components. In fact, radiocarbon dating has been standardized
as an analytical method called ASTM D6866 precisely for this type of determination.

Radiocarbon dating has been used for decades for dating archaeological artifacts. The same
principles of dating (i.e. analysis of the carbon 14 atom) can also be used to measure the
biomass component of materials. In effect, biomass contains a well-characterized amount of
carbon 14 that is easily distinguished from other materials such as fossil fuels that do not contain
any carbon 14. Since the amount of carbon 14 in biomass is well known, a percentage of
biomass carbon can be calculated easily from the overall carbon atoms in the sample.

Although ASTM D6866 is now used throughout the world to measure biomass carbon, the origins
of the method are American. It was written at the request of the USDA to satisfy legislation
requiring Federal agencies to give preferred procurement to manufacturers using the greatest
amount of biomass in their products (per the Farm Security and Rural Investment act of 2002). It
was quickly established that radiocarbon dating was the only viable accurate technique to make
the determination of the biomass percentage. A working standard of radiocarbon dating for
industrial use was completed in 2004 and is now cited in US Federal Law (7 CFR part 2902).

Our firm, Beta Analytic, has been in direct contact for the past year and half with OFGEM with
regard to their Renewable Obligation Certificate program for Energy from Waste Combined Heat
and Power plants. A study was commissioned on behalf of OFGEM by the Renewable Energy
Beta Analytic

Association, with Beta Analytic, Columbia University and Fichtner's participation to demonstrate
the viability of radiocarbon dating for determining the biomass fraction of materials. I have
attached to this email a copy of this study.

The study clearly shows that radiocarbon can accurately determine the biomass fraction of
different materials (see in particular page 20). Furthermore, the study demonstrates that
radiocarbon dating can be used to determine the energy produced from biomass. The same
principals and findings in this report can be used to bolster the use of radiocarbon dating as a
viable analytical method for verifying the biomass fraction of biodiesel and glycerol.

Chapter 3, Question 1: Are there any circumstances in which Biodiesel (produced using methanol
derived from natural gas) would not contain atoms from the natural gas?

In general, we believe that this would not be possible. On the other hand, as stated above,
radiocarbon dating can easily determine whether biodiesel is made with fossil fuel feedstocks.
Precision of the method is excellent with an error of less than +/- 0.3%. We therefore believe that
radiocarbon dating can easily address whether biodiesel is manufactured with methanol derived
from natural gas.

Chapter 3, Question 2: What are your views on this approach to the eligibility of Biodiesel?

As stated above, we believe that radiocarbon dating using the standardized method ASTM D6866
can easily address the issue of eligibility of biodiesel.

Chapter 4, Question 1: What are your views on the proposed interpretations?

We believe some of the interpretations are overly restrictive since radiocarbon dating can address
some, if not all the concerns of the biomass fraction of glycerol.

Chapter 4, Question 2: Do you agree with our preferred option of adopting the total exclusion
interpretation?

We believe that this option is overly restrictive considering that radiocarbon dating can address
some, if not all the concerns of the biomass fraction of glycerol.

Chapter 4, Question 3: Do you agree with our assessment of the benefits and consequences of
each interpretation, and do you foresee any others for either interpretation provided in this
chapter?

Radiocarbon dating is a cost effective method to verify whether glycerol is made with fossil fuel
feedstocks. We therefore believe that the total exclusion suggestion is too restrictive since a
proven analytical is available for determining the biomass fraction of glycerol.

Chapter 4, Question 4: Are there any other valid interpretations that should be evaluated in order
to determine Ofgem's policy on glycerol?

Yes. Ofgem should take into account the composition of the carbon atoms during the
manufacture of both biodiesel and glycerol to make the proper interpretation whether to allow the
use of glycerol in the Renewable Obligations program. As stated above, radiocarbon can be used
to make this determination.

Chapter 4, Question 5 (glycerol's use in Anaerobic Digestion): Would there be any impact on
Anaerobic Digestion if either interpretation for glycerol was adopted? If so would this be
significant?

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Beta Analytic

We believe that it would have an impact, but we are not in the measure to attest how large would
be the impact.

Chapter 4, Question 6 (glycerol's use in Anaerobic Digestion): Is there any information that would
show glycerol's methane producing ability, which Ofgem could use to form our policy and allow us
to determine the renewable fraction of the biogas from an anaerobic digester using glycerol?

Yes. Radiocarbon dating can easily determine the renewable fraction of the biogas from an
anaerobic digester using glycerol. See the answer to question 2, chapter 1 for an explanation of
radiocarbon dating.

Sincerely,

Thierry Sam Tamers


Director

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