Executive Summary
What the report is about
This report examines the environmental and safety regulatory requirements covering the supply and use of biogas flares in Australia and compares them with overseas requirements. It presents information on the costs of flares made in Australia and compares that with those from overseas. The report identifies impediments to a reduction in the cost of flaring systems for agricultural industries and makes recommendations on removing these impediments in order to make biogas capture more viable.

Who is the report targeted at
The research will benefit producers in Australia's intensive livestock industries by providing a clearer understanding of the regulations for biogas flares, in order to clarify expectations and avoid undue delays and costs in the development stages of projects. For the agricultural industry as a whole it will facilitate the uptake of biogas projects, which in turn will provide environmental benefits by reducing the industries’ greenhouse gas emissions.

Background
Where methane in biogas is captured by Australian industries, a flare is always required whether or not other equipment is installed to use the gas. Therefore the cost of providing a flare is always a factor in the cost of a biogas capturing system and will influence its viability. Provision of methane flaring systems in Australian agriculture is perceived to be more costly than it is in other comparable countries due, in part at least, to the requirements of meeting the current Australian environmental standards and Australian manufacturing costs.

Methods used
A literature search was done of both environmental and safety standards covering biogas flares in each of the states of Australian and overseas. Australian state government regulators were also contacted for further information and clarifications.

Agricultural industry groups in Australia likely to use biogas systems were contacted to determine whether the cost of biogas flares had been or was likely to be an issue.

Flare suppliers in Australia and overseas were identified and a number were approached to provide prices for open and enclosed flares over a range of sizes.

Results/Key findings
The cost of biogas flares is seen by many industry participants as being only a small part of any biogas capture project and is therefore not a major factor in the overall project cost. However flares are considered to cost more in Australia than they should, possibly due to local environmental and safety regulations, which are perceived to be strict. This perception could be due to confusion about the application of environmental and safety regulations to biogas, both of which change from state to state.

A clearer understanding of the regulatory requirements may assist agricultural industries to understand what is actually required so that they are able to negotiate with contractors and flare suppliers to get the best value option, rather than the best performing one.

Flare costs in Australia appear to be consistent with European costs and possibly USA, but higher than those in India/Asia. The market in Australia is relatively small and even a threefold increase in the number of flares is not expected to provide the economies of scale required to significantly reduce the price.

Environmental legislation can have a significant impact on flare costs. Good emission performance requires an enclosed, high temperature flare, which costs 1.5-2 times the amount of a simple open flare.

Flares consuming up to 600 SCMH of biogas will not require an environmental license in any state in Australia unless they are on a site or are part of an activity that already requires a license. In this case the environmental limits for the flare will be determined on a case-by-case basis.

Flares that do not require an environmental license are regulated by local councils or authorities. They are covered by local council planning schemes and general guidelines issued by the state government.

The general nature of the guidelines introduces a high degree of subjectivity to the assessment process, or it requires expensive plume dispersion modelling to be undertaken. Although this approach provides flexibility in determining an outcome, it does not provide the simplicity and certainty that more specific guidelines would.

European environmental standards for biogas flaring appear to be more stringent than those in Australia. Less expensive “open” flares are only allowed for emergency or short-term back-up operation.

Each state and territory has its own legislation covering the safety of gas appliances. In Queensland and Victoria the legislation covers appliances using any fuel gas, but in the others it covers only appliances that use gas from a commercial network. A flare using an LPG pilot gas would probably be regulated by gas safety legislation in all states, but a flare using biogas alone would be regulated in Queensland and Victoria only.

The same distinction applies with the Australian Standards for fuel burning appliances. AS 3814/AG 501 (Industrial and Commercial Gas-fired Appliances) applies to flares using LPG pilot fuel, possibly applies to enclosed flares using biogas only, and does not apply to open flares using biogas. However, AS 1375 (Industrial Fuel Fired Appliances Code) applies to all biogas flares.

Implications for relevant stakeholders
Agricultural industries should look at sourcing flares that are manufactured overseas, especially for open flares, which would have less onerous environmental performance requirements.

It is important to determine environmental performance requirements by liaising with the local council or approving authority. This will determine the type of flare required which will have a large influence on the price. Discussions with the council may take some time due to the subjective nature of the assessment so they should be started early in the project development process.

In many states a biogas flare may not be regulated by the gas safety regulator, especially if it does not use an LPG fuelled pilot. This means the onus is on the purchaser to ensure they get a system that complies with the Australian Standard AS 1375 (Industrial Fuel Fired Appliances Code) as a minimum.

Recommendations
Agricultural industries planning to install a biogas system should consult with the office of the gas regulator and the local council early in the project development process.

When developing a biogas project, agricultural industries should ensure quotes are also received for overseas manufactured flares. However the supplier should be responsible for appliance approvals or compliance with AS 1375.

A do-it-yourself approach may be suitable for small, open flare installations not using an LPG pilot flame. However, the person manufacturing and installing the flare must recognise there is a duty of care to ensure the installation meets industry standard health and safety guidelines