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 the Renewables Obligation DRAFT Fuel Measurement and Sampling
Guidance

Dear Mr. Blagrove,

We would like to comment on the question posed in Section 3.39 of the Renewables Obligation:
DRAFT Fuel Measurement and Sampling Guidance document published in December 2008.

Although the potential cost of auditing a generator off-site should best be addressed by verifiers,
we would like to mention that off-site measurement of flue gases is not only feasible but also
economical. This is particularly true for measurement of the biomass fraction of flue gases and,
consequently, the measurement of the biomass fraction of energy produced. In 2007, OFGEM
commissioned a study with the Renewable Energy Association that demonstrated that it is
feasible to measure off-site the biomass energy fraction with radiocarbon dating.

Standardized off-site measurement of the biogenic carbon fraction of fuels by radiocarbon dating
is now available with two standard methods: ASTM D6866 in the US and CEN/TS 15747:2008 in
Europe. These standard methods can determine the biogenic fraction of any gas, liquid, or solid
sample. In the United States, a new method called ASTM D7459-08 was also developed to
standardize the collection of off-site flue gas for biogenic carbon emissions.

Analyzing flue gas samples off-site is particularly advantageous because the resultant gas from
the combustion of multiple fuel samples can be amalgamated into one gas bag. Consequently, a
true representation of the combusted fuel can be measured over the combustion history of
several hours to several months with only one gas bag. The analysis by radiocarbon dating of
one gas sample during a continuous period can be more economical and, more importantly, more
representative when compared to methods that must analyze the solid fuel sample. Several
studies have also demonstrated that radiocarbon dating is more accurate in determining the
biomass fraction of fuels compared to other analytical methods.

Sincerely,

Thierry Sam Tamers

Director