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Swapping from red diesel to HVO fuel


Bosley Dave

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7 minutes ago, Alan de Enfield said:

 

I was reading a report recently where the Governement has categorically stated that HVO will not be subject to any rebate and can only be sold "with full duty and tax"

 

I'll have to see if I can hunt it down again.

My use of the subsidy/rebate concept is an over-simplification and the reality is actually enshrined in the workings of the RTFO/RTFC mechanism .... into which I would not wish anyone to delve!

 

Simplified, HVO used within scope (in this case within the  Non Road Mobile Machinery {NRMM} sector) – which is where inland boats reside – attracts two Road Transport Fuel Certificates (RTFCs) which are worth around £0.40 each. So the fuel distributer sells the HVO at its full cost of something in the region of £2.00/litre and then claims back the two RTFCs where the HVO is being used in NRMMs.

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16 minutes ago, Alan de Enfield said:

 

I was reading a report recently where the Governement has categorically stated that HVO will not be subject to any rebate and can only be sold "with full duty and tax"

 

I'll have to see if I can hunt it down again.

 

 

Edit to add :

 

I have now found this Government documents which suggests that boaters will be able to retain rebates on their heating (domestic) use of HVO but will be required to pay full duty on the propulsion proportion.

 

Check when rebated fuel can be used - GOV.UK (www.gov.uk)

 

The rebated fuels affected by these changes are:

  • rebated diesel
  • rebated Hydrotreated Vegetable Oil (HVO)
  • rebated biodiesel and bioblend
  • kerosene taxed at the rebated diesel rate
  • fuel substitutes

HVO is a liquid hydrocarbon which is classified for excise purposes as heavy oil and treated the same as diesel.

Fully rebated kerosene is unaffected by these changes and can be used for all heating uses.

 

 

 

You can use rebated fuel in all types of boat, except for private pleasure craft in Northern Ireland. This includes in their engines and in other machines and appliances permanently on the boat.

Since 1 October 2021, you cannot put rebated fuel into the fuel supply of the engine of a private pleasure craft in Northern Ireland.

If you buy rebated fuel for private pleasure craft in Great Britain, you will be required to pay the additional duty on the proportion of the fuel you will use to propel the craft.

Find more information about fuel used in private pleasure craft and the changes in Northern Ireland.

This relates purely to duty and is a matter between boater and HMRC. The RTFO/RTFC mechanism is administered by DfT and is levied on cost.

 

I'd like to be able to tell you the there is absolutely no connection between the two ... and in essence there isn't.

 

However, DfT has instructed the fuel distributers, tendering to supply HVO to marinas and boatyards, to tender on the basis that the fuel will be used on a 60:40 split (incorrect, as we know that boaters make their own declaration depending on individual use) so they have to quote this hybrid price. It is here that there is a 'crossover' as this is 'borrowing' from the HMRC duty concept and it is for the convenience of DfT in reconciling volumes of fuel sold.

 

The thrust of the case that IWA etc are building is based on the pragmatism adopted by HMRC in the legislation you quote above, on the basis that with the majority of inland boats having a single tank, the way to go with HVO use should logically follow the: This includes in their engines and in other machines and appliances permanently on the boat route.

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1 hour ago, Thames Bhaji said:

Thanks very much for the update - however hard I try to understand the duty on this I always seem to be a few steps behind! It’s further complicated for us because we are diesel-electric, so the split between generating and propulsion is rather in the eye of the beholder. 
 

We don’t mind spending over the odds at the moment to use a more carbon-neutral fuel. Although technically suppliers will do a bulk supply, they’re not keen because a) less than 1000l isn’t worth putting in a tanker unless they happen to making other deliveries nearby and b) they sound nervous of pumping onto a boat. 
 

I could take 200l barrels, but don’t want to be left with the empty barrels to get rid of. So I might just get a few 20l fuel boxes for now, and hope that other supplies become viable at some point. 

 

I have been running my engine on HVO for a couple of months now and I really like it, there is a very obvious reduction in smoke and the engine sounds significantly nicer, though the JD3 is prone to harsh combustion noise when loaded so other engines might give a lesser noise reduction.

 

I've just ordered another two 200litre drums of red HVO as luckily I currently have space to keep them. Its very expensive but still less than white from the supermarket. Delivery is "free" but it works out significantly cheaper to get two delivered at the same time. 😀

 

The local scrap man might just take the empties if we can't think of something more creative to do with them.

 

I did try to get a 20l fuel box for an initial experiment but it proved impossible so I took the risk and got an initial 200litre drum.

 

Edited by dmr
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1 hour ago, David Mack said:

People will buy them on Ebay.

 

What a good idea, I see they are anything between £5 and £20 collected. I assume the value depends upon location.

£20 is 10p per litre 😀

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1 hour ago, dmr said:

 

What a good idea, I see they are anything between £5 and £20 collected. I assume the value depends upon location.

£20 is 10p per litre 😀

I bought one last year for I think £6. From a funny little man in North Manchester who had several empty drums in his back garden, and told me that he took drums of waste oil from all the local back street car repair places to burn in his central heating boiler. All sounded a bit bit dodgy to me - I'm sure he should have a waste carrier's licence for that sort of thing (and I somehow doubt he had) and the garages should be paying for proper disposal of their waste.

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1 hour ago, David Mack said:

I bought one last year for I think £6. From a funny little man in North Manchester who had several empty drums in his back garden, and told me that he took drums of waste oil from all the local back street car repair places to burn in his central heating boiler. All sounded a bit bit dodgy to me - I'm sure he should have a waste carrier's licence for that sort of thing (and I somehow doubt he had) and the garages should be paying for proper disposal of their waste.

 

Its not just waste carrying, I believe a licence (expensive?) is also needed to burn the stuff.

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1 hour ago, David Mack said:

All sounded a bit bit dodgy to me - I'm sure he should have a waste carrier's licence for that sort of thing

Waste carrier licences used to be free and easy you just had to apply on .gov.uk I used to have  one just to cover myself when leaving site with rubbish in the car. 

37 minutes ago, dmr said:

Its not just waste carrying, I believe a licence (expensive?) is also needed to burn the stuff.

I know of a certain steam boat that used to burn waste oil to generate steam

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6 hours ago, Thames Bhaji said:

Thanks very much for the update - however hard I try to understand the duty on this I always seem to be a few steps behind! It’s further complicated for us because we are diesel-electric, so the split between generating and propulsion is rather in the eye of the beholder. 
 

We don’t mind spending over the odds at the moment to use a more carbon-neutral fuel. Although technically suppliers will do a bulk supply, they’re not keen because a) less than 1000l isn’t worth putting in a tanker unless they happen to making other deliveries nearby and b) they sound nervous of pumping onto a boat. 
 

I could take 200l barrels, but don’t want to be left with the empty barrels to get rid of. So I might just get a few 20l fuel boxes for now, and hope that other supplies become viable at some point. 

I am technically diesel electric as well, we also have solar, I purchased last year a IBC of red HVO from crown oils at 79 pence a litre for the Genny and the Bubble stove no hassle with them 

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In the 1980's the Festiniog railway used to encourage visitors to donate their old engine oil, which they could burn in their locos.  At that time their steam locos were oil-fired as they were not allowed to burn coal due to the risks of sparks setting fire to the forestry commission's woods that the line passed through.

 

A reprise of what the Great Eastern Railway had been doing a century earlier to dispose of the heavy oil that was a waste product from their factory that made illuminating oil for lighting their coaches and stations. They had been dumping it in the River Lea  until the river authority protested, and had had to find another way of getting rid of it. 

Edited by Ronaldo47
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14 hours ago, peterboat said:

I am technically diesel electric as well, we also have solar, I purchased last year a IBC of red HVO from crown oils at 79 pence a litre for the Genny and the Bubble stove no hassle with them 

Repeat the exercise today and Crown will have you filling in forms to declare that the HVO will be used within the NRMM sector. Without them they are unable to reclaim the two RTFCs per litre so they are justifiably nervous.

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7 hours ago, MtB said:

 

I guess you don't now or you'd know it costs £154.00.

 

https://www.gov.uk/register-renew-waste-carrier-broker-dealer-england

 

It still is free if you carry your own waste as I was doing, 

 

"Registration is usually free if you only transport waste you produce yourself. Otherwise, registration costs £154."

 

So if you are paying £154 and only carrying your own waste then .......................

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9 hours ago, Loddon said:

It still is free if you carry your own waste as I was doing, 

 

 

Not necessarily. Waste you produce yourself has a pretty narrow definition. If the waste you "produce yourself" is in any way connected with business, you still need the 'paid for' version.

 

But the subsidiary point being, the title of the license is misleading. If you generate any waste by way of business but leave it on site and don't carry it anywhere, you STILL need the license! (IIRC). 

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  • 1 month later...

Have been running my Beta JD3 on HVO for a bit now and am very impressed. Myrecent  order for another 400litres got very complicated as the only delivery truck was too big to get up the little road here. After much delay and admin we collected it from the local transport depot (with additional complications about transport of dangerous goods). When I orderred it it was really expensive but by the time we collected it it was a real bargain.

Engine has done 13000 hours and is just starting to use a bit of oil. After switching to HVO oil consumption is back to zero, very odd, maybe just a co-incidence or error in measuring consumption.

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10 minutes ago, dmr said:

Have been running my Beta JD3 on HVO for a bit now and am very impressed. Myrecent  order for another 400litres got very complicated as the only delivery truck was too big to get up the little road here. After much delay and admin we collected it from the local transport depot (with additional complications about transport of dangerous goods). When I orderred it it was really expensive but by the time we collected it it was a real bargain.

Engine has done 13000 hours and is just starting to use a bit of oil. After switching to HVO oil consumption is back to zero, very odd, maybe just a co-incidence or error in measuring consumption.

 

 

I think you may have been misinformed - why were the carriage of dangerous goods regs invoked ?

 

Firstly diesel (and presumambly HVO) is not classed as 'dangerous goods' :

(Note CDG 2009 = carriage of dangerous goods act 2009)


 

 

Diesel with a flash-point above 100°C is not considered dangerous for carriage and is not therefore covered by the CDG 2009.

Note: ‘red diesel’ is also covered by these classifications. It is not a separate type of diesel for the purposes of carriage. ‘Red diesel’ is coloured for fuel taxation purposes rather than safety.

 

Secondly you are allowed to carry up to 1000 litres as an exemption to the ADR regulations (This is why my Bowser is rated at 900 litres although it will carry over 1000 litres)

 

Diesel is assigned to Transport Category 3 in ADR , which permits carriage of up to 1,000 litres in UN -approved packages per transport unit (a motor vehicle with or without an attached trailer) without most of the CDG 2009 applying

 

 

ADR 1.1.3.1(a) states that the provisions laid down in ADR do not apply to:

The carriage of dangerous goods by private individuals where the goods in question are packaged for retail sale and are intended for their personal or domestic use or for their leisure or sporting activities provided that measures have been taken to prevent any leakage of contents in normal conditions of carriage.

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5 hours ago, Alan de Enfield said:

 

 

I think you may have been misinformed - why were the carriage of dangerous goods regs invoked ?

 

Firstly diesel (and presumambly HVO) is not classed as 'dangerous goods' :

(Note CDG 2009 = carriage of dangerous goods act 2009)


 

 

Diesel with a flash-point above 100°C is not considered dangerous for carriage and is not therefore covered by the CDG 2009.

Note: ‘red diesel’ is also covered by these classifications. It is not a separate type of diesel for the purposes of carriage. ‘Red diesel’ is coloured for fuel taxation purposes rather than safety.

 

Secondly you are allowed to carry up to 1000 litres as an exemption to the ADR regulations (This is why my Bowser is rated at 900 litres although it will carry over 1000 litres)

 

Diesel is assigned to Transport Category 3 in ADR , which permits carriage of up to 1,000 litres in UN -approved packages per transport unit (a motor vehicle with or without an attached trailer) without most of the CDG 2009 applying

 

 

ADR 1.1.3.1(a) states that the provisions laid down in ADR do not apply to:

The carriage of dangerous goods by private individuals where the goods in question are packaged for retail sale and are intended for their personal or domestic use or for their leisure or sporting activities provided that measures have been taken to prevent any leakage of contents in normal conditions of carriage.

 

Until the 2009 CDG revision, diesel had an "official" flashpoint of 79°C and was in scope of both CDG and ADR.

 

When I was working for BT I had numererous batches of diesel tested, and the flashpoint was always over 100°C, but we still had to comply by hsving a Dangerous Goods Safety Adviser and ADR trained drivers, despite showing the DoT the evidence.

 

Glad to see that common sense has finally prevailed.

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7 hours ago, Alan de Enfield said:

 

 

I think you may have been misinformed - why were the carriage of dangerous goods regs invoked ?

 

Firstly diesel (and presumambly HVO) is not classed as 'dangerous goods' :

(Note CDG 2009 = carriage of dangerous goods act 2009)


 

 

Diesel with a flash-point above 100°C is not considered dangerous for carriage and is not therefore covered by the CDG 2009.

Note: ‘red diesel’ is also covered by these classifications. It is not a separate type of diesel for the purposes of carriage. ‘Red diesel’ is coloured for fuel taxation purposes rather than safety.

 

Secondly you are allowed to carry up to 1000 litres as an exemption to the ADR regulations (This is why my Bowser is rated at 900 litres although it will carry over 1000 litres)

 

Diesel is assigned to Transport Category 3 in ADR , which permits carriage of up to 1,000 litres in UN -approved packages per transport unit (a motor vehicle with or without an attached trailer) without most of the CDG 2009 applying

 

 

ADR 1.1.3.1(a) states that the provisions laid down in ADR do not apply to:

The carriage of dangerous goods by private individuals where the goods in question are packaged for retail sale and are intended for their personal or domestic use or for their leisure or sporting activities provided that measures have been taken to prevent any leakage of contents in normal conditions of carriage.

 

But I think the flash point is 60 so it is coverred by ADR?. There is, as yiou say, an exemption for less than 1000litres total with no more than 400l in a single approved container if the fuel is for ones personal use. The drums were labelled as hazardous. I had sorted this out previously with the distribution centre who had to get confirmation from the supplier. Unfortunately when we turned up at the huge new distribution centre in our old beaten up flatbed Transit the man who we had dealt with was off sick and nobody else knew about the exemption. Luckily I had rememberred it was 1.1.3.1 and managed to blag. They said "I bet you are making that up" but let us take the fuel. 

My initial plan was to meet the big truck in a layby and transfer the drums to the Transit but it appears that fuel can not be delivered to a layby.

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2 hours ago, MartynG said:

How much was the HVO per litre ,if you dont mind me asking?

I paid £1.41, this was just as fuel prices started to rise. I don't think getting fuel delivered in 200 litre drums is the cheapest way to do it as there must be a significant delivery charge, and the cost of the drum.  I suspect it is much more expensive now.

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6 minutes ago, dmr said:

I paid £1.41, this was just as fuel prices started to rise. I don't think getting fuel delivered in 200 litre drums is the cheapest way to do it as there must be a significant delivery charge, and the cost of the drum.  I suspect it is much more expensive now.

I wondered if HVO  would now be cheaper than diesel but it seems not.

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25 minutes ago, MartynG said:

I wondered if HVO  would now be cheaper than diesel but it seems not.

 

I think it is locked to the price of diesel plus quite a few pence more, so as the diesel prices go up somebody must be making a lot of money. I suppose if it was cheaper everybody would want it so those dreaded market forces would put the price up anyway.

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On 28/02/2022 at 07:58, MtB said:

 

 

Not necessarily. Waste you produce yourself has a pretty narrow definition. If the waste you "produce yourself" is in any way connected with business, you still need the 'paid for' version.

 

But the subsidiary point being, the title of the license is misleading. If you generate any waste by way of business but leave it on site and don't carry it anywhere, you STILL need the license! (IIRC). 

Get WRG to move it for you

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