Proposed Am endm ents Fuel Quality Directive Malcolm Fendick - - PDF document

Proposed Am endm ents to the Fuel Quality Directive

Malcolm Fendick Malcolm Fendick

The Fuel Quality Directive 9 8 / 7 0 / EC

• Deals only with fuels for surface transport
• Is concerned with the quality of petrol, diesel, and gas
• il (“red diesel”) for use in road transport, on inland

waterways, and for railway locomotives and mobile plant

• Controls those aspects of fuel quality with a bearing on

the environment and health

• Deals only with fuels for surface transport
• Is concerned with the quality of petrol, diesel, and gas
• il (“red diesel”) for use in road transport, on inland

waterways, and for railway locomotives and mobile plant

• Controls those aspects of fuel quality with a bearing on

the environment and health

The Proposed Am endm ent

• Contains eight principal points
• Is primarily intended to permit and encourage the use
• f biofuels
• Also addresses some air quality issues
• Would set Greenhouse Gas reduction targets
• Contains eight principal points
• Is primarily intended to permit and encourage the use
• f biofuels
• Also addresses some air quality issues
• Would set Greenhouse Gas reduction targets

The Eight Points

• Lifecycle Greenhouse Gas reduction targets for fuels
• Introduction of separate E5 and E10 fuel grades
• Alterations to the summer vapour pressure relaxation
• Reduction in the sulphur content of gas oil
• Introduction of a vapour pressure waiver for fuel containing ethanol
• Reduction in the PAH content of diesel fuel
• The development of a test methodology for metallic fuel additives
• Possible complete disappearance of leaded petrol
• Lifecycle Greenhouse Gas reduction targets for fuels
• Introduction of separate E5 and E10 fuel grades
• Alterations to the summer vapour pressure relaxation
• Reduction in the sulphur content of gas oil
• Introduction of a vapour pressure waiver for fuel containing ethanol
• Reduction in the PAH content of diesel fuel
• The development of a test methodology for metallic fuel additives
• Possible complete disappearance of leaded petrol

Separate E5 and E1 0 Fuel Grades

• Petrol may currently contain up to 5% ethanol
• Would introduce an additional 10% ethanol grade
• Intended to assist roll-out of bioethanol

Our View

• Two separately labelled grades would be an unnecessary complication for

the consumer and a burden upon the distribution chain

• Vehicle operability problems with a 10% ethanol blend should be minimal
• Allowing all petrol to contain up to 10% ethanol would be simpler
• Petrol may currently contain up to 5% ethanol
• Would introduce an additional 10% ethanol grade
• Intended to assist roll-out of bioethanol

Our View

• Two separately labelled grades would be an unnecessary complication for

the consumer and a burden upon the distribution chain

• Vehicle operability problems with a 10% ethanol blend should be minimal
• Allowing all petrol to contain up to 10% ethanol would be simpler

The Sum m er Vapour Pressure Relaxation

• The permitted vapour pressure of petrol is lower in the summer in order to

reduce evaporation

• Member States with “Arctic” summer conditions are allowed a relaxation of

the summer vapour pressure requirement

• The proposal would limit the relaxation to states with cold winter conditions

Our View

• The proposal is illogical because the correlation between cold winters and

cold summers is poor

• Loss of this relaxation is undesirable because it will lead to potential starting

difficulties in colder summer weather in the United Kingdom

• The permitted vapour pressure of petrol is lower in the summer in order to

reduce evaporation

• Member States with “Arctic” summer conditions are allowed a relaxation of

the summer vapour pressure requirement

• The proposal would limit the relaxation to states with cold winter conditions

Our View

• The proposal is illogical because the correlation between cold winters and

cold summers is poor

• Loss of this relaxation is undesirable because it will lead to potential starting

difficulties in colder summer weather in the United Kingdom

The Sulphur Content of Gas Oil

• A substantial reduction in two stages to almost sulphur-free by 2010 in order

to permit use of catalytic emissions control technologies

• A delayed introduction for inland waterway fuel, where catalysts will not be

required in the near future Our View

• The United Kingdom supports the principle of sulphur-free gas oil
• A requirement that gas oil was strictly “sulphur free” at the point of delivery

might pose cross-contamination problems for distributors

• Delaying application to the rail sector until it was technically required would

avoid unnecessary costs falling on that sector

• A substantial reduction in two stages to almost sulphur-free by 2010 in order

to permit use of catalytic emissions control technologies

• A delayed introduction for inland waterway fuel, where catalysts will not be

required in the near future Our View

• The United Kingdom supports the principle of sulphur-free gas oil
• A requirement that gas oil was strictly “sulphur free” at the point of delivery

might pose cross-contamination problems for distributors

• Delaying application to the rail sector until it was technically required would

avoid unnecessary costs falling on that sector

The Ethanol Vapour-Pressure W aiver

• Would introduce a vapour-pressure waiver for fuel containing ethanol
• n a sliding scale
• Would allow for the fact that higher ethanol content increases vapour-

pressure Our View

• This provision is not really necessary, and will increase evaporative

emissions

• The suggested palliative, of recovering vapour at petrol stations, may

be less cost effective than leaving vapour-pressure limits as they are

• Would introduce a vapour-pressure waiver for fuel containing ethanol
• n a sliding scale
• Would allow for the fact that higher ethanol content increases vapour-

pressure Our View

• This provision is not really necessary, and will increase evaporative

emissions

• The suggested palliative, of recovering vapour at petrol stations, may

be less cost effective than leaving vapour-pressure limits as they are

Polycyclic Arom atic Hydrocarbon ( PAH) Content

• The PAH content of diesel would be reduced from 11% by mass to 8%
• Intended to control PAH emissions, many of which are carcinogenic

Our View

• United Kingdom diesel already meets the lower limit
• The air quality benefits of reducing PAH in fuel are not well supported

by available data

• Meeting the lower limit in the future might disproportionately increase

refinery carbon dioxide emissions

• The PAH content of diesel would be reduced from 11% by mass to 8%
• Intended to control PAH emissions, many of which are carcinogenic

Our View

• United Kingdom diesel already meets the lower limit
• The air quality benefits of reducing PAH in fuel are not well supported

by available data

• Meeting the lower limit in the future might disproportionately increase

refinery carbon dioxide emissions

The Developm ent of a Test Methodology for Metallic Fuel Additives

• There are currently no legislative restrictions on the use of metallic fuel

additives

• Metallic fuel additives are not widely used in the European Union at present
• There are concerns that some additives might damage emissions control

technologies, or result in uncontrolled emissions which might damage health Our View

• The United Kingdom supports the proposal that a test methodology for

approval of metallic additives should be produced

• There are currently no legislative restrictions on the use of metallic fuel

additives

• Metallic fuel additives are not widely used in the European Union at present
• There are concerns that some additives might damage emissions control

technologies, or result in uncontrolled emissions which might damage health Our View

• The United Kingdom supports the proposal that a test methodology for

approval of metallic additives should be produced

Leaded Petrol

• Member States are currently permitted to sell up to half a percent of their total

petrol sales as leaded petrol

• No proposal on leaded petrol was made by the European Commission
• Some Member States would like the proposal amended to prevent any future

sales of leaded petrol Our View

• Leaded petrol in the United Kingdom is provided by a small number of

specialist fuel suppliers, largely as a service to owners of classic vehicles

• Our air quality objectives on lead are met, and the amount of fuel sold is

insignificant in environmental terms

• Member States are currently permitted to sell up to half a percent of their total

petrol sales as leaded petrol

• No proposal on leaded petrol was made by the European Commission
• Some Member States would like the proposal amended to prevent any future

sales of leaded petrol Our View

• Leaded petrol in the United Kingdom is provided by a small number of

specialist fuel suppliers, largely as a service to owners of classic vehicles

• Our air quality objectives on lead are met, and the amount of fuel sold is

insignificant in environmental terms

Lifecycle Greenhouse Gas Reduction Targets for Fuels

The Proposal

• Fuel suppliers would be required to report the lifecycle

Greenhouse Gas emissions of their fuels

• Greenhouse Gas emissions would have to be reduced by

1% per year per unit of fuel energy between 2010 and 2020, using 2010 as a baseline The Proposal

• Fuel suppliers would be required to report the lifecycle

Greenhouse Gas emissions of their fuels

• Greenhouse Gas emissions would have to be reduced by

1% per year per unit of fuel energy between 2010 and 2020, using 2010 as a baseline

Lifecycle Greenhouse Gas Reduction Targets for Fuels

The Background

• The Environment Ministers’ Spring Council agreed a 10% biofuels by

energy content target

• The Spring Council agreement was subject to provisos on

sustainability, commercial availability of second-generation biofuels, and amendment of the Fuel Quality Directive to permit higher biofuel blending levels

• The Spring Council agreement is fully compatible with the United

Kingdom’s position on any evolution of our Renewable Transport Fuel Obligation after 2010 The Background

• The Environment Ministers’ Spring Council agreed a 10% biofuels by

energy content target

• The Spring Council agreement was subject to provisos on

sustainability, commercial availability of second-generation biofuels, and amendment of the Fuel Quality Directive to permit higher biofuel blending levels

• The Spring Council agreement is fully compatible with the United

Kingdom’s position on any evolution of our Renewable Transport Fuel Obligation after 2010

Lifecycle Greenhouse Gas Reduction Targets for Fuels

The Problem

• The target is much more ambitious than that agreed at the Spring Council
• The UK, and some other Member States, will already have about 5% biofuel

by volume in the 2010 baseline year

• The uptake of large quantities of biofuel would be the only practical way of

meeting the target

• Biofuels currently offer a carbon dioxide reduction of about 50% by

comparison with fossil fuels

• The target ignores the possibility of an increase in Greenhouse Gas

emissions from extraction of fossil fuels The Problem

• The target is much more ambitious than that agreed at the Spring Council
• The UK, and some other Member States, will already have about 5% biofuel

by volume in the 2010 baseline year

• The uptake of large quantities of biofuel would be the only practical way of

meeting the target

• Biofuels currently offer a carbon dioxide reduction of about 50% by

comparison with fossil fuels

• The target ignores the possibility of an increase in Greenhouse Gas

emissions from extraction of fossil fuels

Lifecycle Greenhouse Gas Reduction Targets for Fuels

Our Concerns

• There is, as yet, no reliable or agreed methodology for

assessing lifecycle Greenhouse Gas emissions

• The proposal appears to have been made without any

consideration having been given to the sustainability implications of requiring a large increase in uptake of biofuels in a relatively short time Our Concerns

• There is, as yet, no reliable or agreed methodology for

assessing lifecycle Greenhouse Gas emissions

• The proposal appears to have been made without any

consideration having been given to the sustainability implications of requiring a large increase in uptake of biofuels in a relatively short time

Sustainability

• The United Kingdom is investing heavily in the

development of sustainability criteria and a greenhouse gas accounting methodology

• Developing the criteria and the methodology could take as

long as two more years

• Establishing confidence in the criteria and methodology

that we develop will require experience of their operation in the real world

• The United Kingdom is investing heavily in the

development of sustainability criteria and a greenhouse gas accounting methodology

• Developing the criteria and the methodology could take as

long as two more years

• Establishing confidence in the criteria and methodology

that we develop will require experience of their operation in the real world

Sustainability

• Savings in Greenhouse Gas emissions compared with fossil fuels
• Environmental considerations, including preservation of carbon

stocks, biodiversity, and the quality of soil, air , and water

• Social aspects, including workers’ rights and preservation of

communities and of land rights

• Economic aspects, including avoidance of excessive subsidies and

distortion of the market for biofuels, and the price and security of food supplies, especially to the poorest consumers

• Savings in Greenhouse Gas emissions compared with fossil fuels
• Environmental considerations, including preservation of carbon

stocks, biodiversity, and the quality of soil, air , and water

• Social aspects, including workers’ rights and preservation of

communities and of land rights

• Economic aspects, including avoidance of excessive subsidies and

distortion of the market for biofuels, and the price and security of food supplies, especially to the poorest consumers

Consultation ends 2 2 Novem ber