National Fuel Quality Standards Regulation Impact Statement 1 ...
National Fuel Quality Standards Regulation Impact Statement 1 ...
National Fuel Quality Standards Regulation Impact Statement 1 ...
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1 Introduction<br />
<strong>National</strong> <strong>Fuel</strong> <strong>Quality</strong> <strong>Standards</strong><br />
<strong>Regulation</strong> <strong>Impact</strong> <strong>Statement</strong><br />
The transport sector is the single largest contributor to urban ambient air pollution. It is<br />
also one of the largest contributors to national greenhouse gas emissions. The nature of<br />
the problem is such that an integrated strategy, coordinating action across a number of<br />
different areas, is required to address the issue.<br />
The major policy directions for dealing with pollution and greenhouse gas emissions<br />
from vehicles are: to reduce their use, to clean up their emissions and to make them more<br />
fuel efficient. In Australia, three interrelated strategies are being implemented to ‘clean<br />
up’ vehicle emissions. Vehicles are required to meet effective emission standards when<br />
they first enter the market, they will be required to continue to meet effective emission<br />
standards while they are in use; and they will be provided with the cleanest, economically<br />
viable fuels on which to operate.<br />
New vehicle emission standards, harmonising Australian standards with international<br />
vehicle emission standards, were gazetted in December 1999. The quality of fuel in<br />
Australia has been a key constraint to the introduction of new vehicle emission standards.<br />
Emerging vehicle engine and emission control technologies, needed to meet the new<br />
standards and help achieve reductions in fuel consumption, are affected by the quality of<br />
the fuel used.<br />
The Government has already made a number of policy decisions that have a direct<br />
bearing on the future management of fuel quality. The Measures for a Better<br />
Environment (MBE) package, announced by the Prime Minister in May 1999, included a<br />
commitment to reduce sulfur content levels in diesel fuel, and foreshadowed sulfur<br />
content and octane changes to the composition of petrol. The Downstream Petroleum<br />
Products Action Agenda, approved by Cabinet and released in November 1999, advised<br />
of the Government’s intention to have fuel specifications implemented on a national<br />
basis. In December 1999 Cabinet directed the Minister for the Environment and Heritage<br />
to develop Commonwealth legislation to implement national fuel standards.<br />
2 THE PROBLEM - WORSENING URBAN AIR QUALITY AND INCREASING<br />
GREENHOUSE GAS EMISSIONS<br />
Transport is the most significant contributor to ambient air pollution in urban Australia,<br />
with vehicles estimated to contribute up to 70% of total urban air pollution (NSW EPA,<br />
1999). Motor vehicle emissions are key sources of lead, carbon monoxide and nitrogen<br />
dioxide. They are also the major source of photochemical smog (‘ozone’) precursors.<br />
With the exception of particles, petrol passenger vehicles are the major transport source.<br />
Heavy diesel vehicles are also a significant source of nitrogen oxides (NOx). The diesel<br />
fleet is the major transport source of particles, contributing up to 80% of vehicle<br />
produced particles in major cities (NEPC, 1998).
Table 2.1 Contribution (%) of motor vehicles to air emissions in major Australian<br />
cities<br />
Carbon monoxide<br />
(CO)<br />
Hydrocarbons<br />
(HC)<br />
Oxides of nitrogen<br />
(NOx)<br />
Particulates<br />
(PM)<br />
70-95% 40-50% 70-80% 10-50%<br />
Source: Coffey Partners, 1996<br />
Recent research (Carnovale et al, 1991; James, 1994; RTA, 1994; Ballantyne, 1995;<br />
NSW EPA, 1996c; AATSE, 1997; WA DEP, 1997) indicates that unless further action is<br />
taken to improve the management of transport emissions, air quality is likely to decline in<br />
the medium to long term. The principal causes will be population growth, urbanisation<br />
and increased use of motor vehicles.<br />
High levels of air pollutants have been shown to result in a wide range of adverse health<br />
effects including respiratory effects, ranging in severity from coughs, chest congestion,<br />
asthma, to chronic illness and possible premature death in susceptible people.<br />
As shown in Table 2.2, the transport sector contributed about 16% of national greenhouse<br />
gas emissions in 1998. Transport sector emissions rose by 18% during 1990-98. Road<br />
transport is the largest contributor to transport emissions and makes up 14% of total<br />
national emissions. The average rate of increase in road transport emissions over the<br />
period 1990 to 1998 was about 2% per annum. Passenger cars contributed 9% of national<br />
emissions, or 57% of total transport sector emissions in 1998.
Table 2.2 Greenhouse gas emissions from the transport sector in 1998<br />
Sub-sector<br />
Cars and<br />
wagons<br />
Light<br />
commercial<br />
CO2-e emission<br />
Mt<br />
Share of Transport Sector<br />
%<br />
40.95 56.4 8.98<br />
9.11 12.5 2<br />
Medium trucks 2.77 3.8 0.61<br />
Heavy trucks 10.5 14.5 2.3<br />
Buses 1.28 1.8 0.28<br />
Motorcycles 0.21 0.3 0.05<br />
Road Total 64.81 89.3 14.22<br />
Transport total 72.61 100 15.93<br />
<strong>National</strong> total 455.9 - 100<br />
From NGGI 1998<br />
2.1 URBAN AIR QUALITY<br />
Share of <strong>National</strong> Total<br />
%<br />
Australia is one of the most highly urbanised countries in the world, and air pollution is a<br />
significant issue for the community. Surveys of community attitudes have found that<br />
environmental issues are of major concern to the public, with air pollution a key ongoing<br />
concern (NRMA, 1996a; NSW EPA, 1994; Clean Air 2000, 1997; ANOP, 1993). While<br />
the 1996 Australian State of the Environment Report (SoE, 1996) found that the air<br />
quality in the cities and towns of Australia was quite good by international standards,<br />
relatively high concentrations of pollutants are experienced in our larger cities (NEPC,<br />
1997).<br />
Australian national ambient air quality standards were established for the six criteria<br />
pollutants in 1998 (see Table 2.3 below). Of these, the pollutants of current concern are<br />
nitrogen dioxide (NO2), ozone (O3), fine particles (PM10) and, to a lesser extent, carbon<br />
monoxide (CO).
Table 2.3 <strong>National</strong> ambient air quality standards<br />
Pollutant<br />
Averaging<br />
Period<br />
Maximum<br />
Concentration<br />
Carbon monoxide 8 hours 9.0 ppm<br />
Goal within 10 years<br />
(Max allowable<br />
exceedences)<br />
1 day a year<br />
Nitrogen dioxide 1 hour 0.12 ppm 1 day a year<br />
Photochemical oxidant (as<br />
ozone)<br />
Sulfur dioxide<br />
1 year 0.03 ppm None<br />
1 hour<br />
0.10ppm 1 day a year<br />
4 hours 0.08ppm 1 day a year<br />
1 hour<br />
1 day<br />
1 year<br />
0.20ppm<br />
0.08ppm<br />
0.02ppm<br />
Lead 1 year 0.05 µg/m 3<br />
Particles as PM10 1 day 50 µg/m 3<br />
Source: NEPC, 1998<br />
1 day a year<br />
1 day a year<br />
none<br />
none<br />
5 days a year<br />
Concern has also recently been expressed in relation to increased ambient concentrations<br />
of `air toxics'. These are pollutants that occur in relatively small volumes (compared with<br />
criteria pollutants) but are considered hazardous to health or the environment. Motor<br />
vehicle emissions have been estimated to contribute up to 80% of benzene, 57% of<br />
toluene, 76% of butadiene, 64% of formaldehyde, 42% of polyaromatic hydrocarbons<br />
and 57% of xylene in urban environments (EPA Victoria, 1999).<br />
2.1.1 Health effects of urban air pollution<br />
Ambient air quality standards are set at levels to protect the more susceptible members of<br />
society, and significant breaches of these standards represent undesirable impacts on<br />
community health. The most common pollutants discharged to the air are oxides of<br />
nitrogen (NOx), carbon monoxide (CO), hydrocarbons (HC), sulfur dioxide (SO2), and<br />
fine particles (including lead). These pollutants are largely produced by the combustion
of fossil fuels. Another significant pollutant in major urban areas is ozone (O3), a<br />
secondary pollutant formed in sunlight by chemical reactions between NOx and reactive<br />
hydrocarbons.<br />
The adverse health effects, and current ambient concentrations/trends of those pollutants<br />
with a strong linkage to motor vehicles are briefly discussed below (Grant et al, 1993;<br />
Sivak, 1993; NEPC, 1997; NSW EPA, 1996b; Vic EPA, 1994).<br />
Carbon monoxide (CO) Carbon monoxide is a colourless, odourless and tasteless gas<br />
that, in high concentrations, is poisonous to humans. In sufficiently high concentrations<br />
and long exposures, CO interferes with the blood’s capacity to carry oxygen. Exposure at<br />
lower levels can have adverse effects on individuals with cardiovascular disease.<br />
Exceedances of CO standards still occur in Australia’s larger cities, but the number of<br />
events has reduced considerably over the past 10 years. The general consensus is that the<br />
current CO levels are not of significant concern and will continue to decrease (SoE,<br />
1996) as tighter vehicle emission standards come into effect.<br />
Nitrogen dioxide (NO2) Nitrogen dioxide is a pungent acid gas. In the atmosphere it<br />
may irritate respiratory systems, exacerbate asthma in susceptible individuals, increase<br />
susceptibility to cardiovascular disease symptoms and respiratory infections, and reduce<br />
lung function. As a precursor to photochemical smog, it also contributes to effects<br />
associated with ozone.<br />
The NSW Health Department’s Health and Research Program (HARP) examined the<br />
health effects of urban air pollution (Hensley, 1996; Morgan et al, 1998). The HARP<br />
study estimated that days of high NO2 levels were associated with: a 7% increase in<br />
hospital admissions for cardiovascular disease; a 5% increase in childhood asthma<br />
admissions; a 3% increase in adult asthma admissions and a 5% increase in chronic<br />
obstructive pulmonary disease admissions.<br />
While the number of breaches of the current NO2 standard have been low in recent years,<br />
the formation of NO2 in the atmosphere (from nitric oxide in vehicle exhaust) is strongly<br />
affected by seasonal weather conditions. This has lead to a number of reports concluding<br />
that there are no clear trends in NO2 levels (NSW EPA, 1996b, Coffey Partners, 1996).<br />
For example, in Melbourne, while the number of exceedences is low, analysis of the peak<br />
data at the 98 percentile level (a reliable indicator of trends) concludes that a clear<br />
downward trend is not apparent in 1 hour average NOX or NO2 data (Coffey Partners,<br />
1996).<br />
Ozone (O3) Ozone is a gas with strong oxidising properties. Health effects attributed to<br />
ozone include irritation of eyes and airways, exacerbation of asthma symptoms in<br />
susceptible people, increased susceptibility to infection, and acute respiratory symptoms<br />
such as coughing. Ozone also has adverse effects on vegetation and other materials.<br />
The national 1 hour ozone standard (0.10ppm) is exceeded on an annual basis in<br />
Melbourne, Sydney Brisbane and Perth. Adelaide also experiences some exceedences of<br />
the standard. By international standards, the maximum 1 hour ozone concentrations
ecorded in Sydney and Melbourne are comparable with cities such as Toronto, San<br />
Diego, Philadelphia and Atlanta, and exceed those in London.<br />
Until recently, breaches of the standard in most Australian cities have declined steadily.<br />
However, adoption of the more stringent World Health Organisation 1 hour goal<br />
(0.08ppm) would indicate a significantly higher number of recorded exceedences, and a<br />
worsening upward trend. For example, in Sydney the number of exceedences in 1994,<br />
based on 0.12ppm, 0.10ppm and 0.08ppm goals, were 2, 12 and 25 days respectively<br />
(NSW EPA, 1996a). A 1 hour standard of 0.08ppm is the current goal in Western<br />
Australia, and has been identified by NSW as a long term objective (NSW EPA, 1996b).<br />
Fine particles (also referred to as particulate matter or PM) Respirable particles,<br />
those with a diameter of less than 10 µm (PM10), are a particular health concern because<br />
they are easily inhaled and retained in the lung. Almost all of the particles in diesel<br />
exhaust are less than 1 µm in diameter (Concawe, 1998), and diesel particles also adsorb<br />
unburnt hydrocarbons and other potentially carcinogenic organic compounds such as<br />
polycyclic aromatic hydrocarbons. The International Agency for Research on Cancer has<br />
concluded that diesel exhaust is a probable human carcinogen (California Air Resources<br />
Board 1994), and the California Air Resources Board has proposed that diesel exhaust be<br />
classified as a toxic air contaminant (California Air Resources Board, 1998).<br />
Although the mechanisms are not clear, epidemiological studies in the US and elsewhere<br />
consistently show a relationship between particles and a range of respiratory,<br />
cardiovascular and cancer related morbidity and mortality (Concawe, 1996; Ballantyne,<br />
1995; NEPC, 1997). The NSW HARP study estimated that<br />
particle pollution contributed to nearly 400 (2%) premature deaths in Sydney each year<br />
between 1989 and 1993. The study also estimated that days of high particle<br />
concentrations were associated with a 3.5% increase in hospital emissions for<br />
cardiovascular disease, a 3% increase in chronic obstructive pulmonary disease hospital<br />
admissions, and a 3% increase in heart disease admissions in the elderly.<br />
Measurements of PM10 in urban areas indicate that levels are well below current US EPA<br />
standards, but can exceed Californian standards, with annual average levels being around<br />
25 to 40 µg/m 3 and peak 24-hour average levels around 90 to 110 µg/m 3 . Particle<br />
concentrations vary with season, higher values occurring in the autumn/winter months. In<br />
areas where wood smoke from domestic fires dominates, particle levels higher than 150<br />
µg/m 3 (as a 24-hour average) have been recorded on occasion.<br />
2.2 GREENHOUSE GAS EMISSIONS<br />
Scientific evidence points to a discernible human influence on global warming and<br />
climate. There has been a 30% increase in the amount of carbon dioxide in the<br />
atmosphere since the beginning of the industrial revolution, mostly arising from burning<br />
fossil fuels. The earth's temperature has increased during the same period and is now<br />
warmer than at any time during the last 420,000 years.<br />
There are also other effects on climate such as decreasing number of days with frost and<br />
changes to the frequency and intensity of el nino episodes. Though the complex
interactions with the terrestrial and marine ecosystems are not fully understood, the<br />
changing climate is affecting these systems. The long-term impacts of increased levels of<br />
greenhouse gas emissions include:<br />
- rising sea levels, causing flooding of low-lying areas, significant impacts on coastal<br />
ecosystems and other damage;<br />
- shifting climatic zones (and thus ecosystems and agricultural zones) towards the polar<br />
regions;<br />
- new climatic stresses affecting forests, deserts, rangelands and other ecosystems leading<br />
to adverse impacts on biodiversity;<br />
- changes in rainfall patterns, with decreases in rainfall expected for many regions of<br />
Australia leading to changes in water supply and agricultural productivity; and<br />
- effects on infrastructure and human health with consequential impacts on the insurance<br />
and finance industries.<br />
Under the Kyoto Protocol to the United Nations Framework Convention on Climate<br />
Change (as agreed in December 1997 and signed by Australia on 29 April 1998),<br />
Australia is committed to a target for national greenhouse gas emissions of 8% above<br />
1990 levels by 2008-12. This represents about a 30% reduction against current business<br />
as usual projections of greenhouse gas emissions for the period 2008-12.<br />
The 1998 <strong>National</strong> Greenhouse Gas Inventory indicates that from 1990 to 1998 national<br />
transport emissions grew by 18%. In 1998 the transport sector was the third largest<br />
contributor to national greenhouse gas emissions, with about 16% (72.6 Mt) of<br />
Australia’s net emissions. Road transport is the largest contributor to transport emissions<br />
(89%) and makes up 14% of total national emissions. Emissions from passenger vehicles<br />
predominate, but light commercial vehicles are a fast growing source. Passenger cars<br />
contributed 9% of national emissions, or 57% of total transport sector emissions in<br />
1998.The outlook for greenhouse gas emissions from the transport sector continues to be<br />
of serious concern. Without reduction measures, emissions from the transport sector are<br />
predicted to increase by 38% above 1990 levels by the year 2010.<br />
2.3 GOVERNMENT INTERVENTION<br />
Government intervention is necessary because of the mechanism used to manage<br />
tailpipe emissions. Mandatory vehicle emission standards are established as<br />
Australian Design Rules (ADRs) under the Motor Vehicle <strong>Standards</strong> Act 1989. The<br />
gazettal of new, tighter emission standards effectively requires vehicle<br />
manufacturers to adopt new vehicle and emission control technologies. Existing<br />
Australian fuel quality is a constraint to the effective functioning of many of these<br />
new technolo<br />
Government intervention will ensure that any fuel standards are applied equally in respect<br />
of imports as well as domestically produced petroleum fuels and are compatible with
elevant international or internationally accepted standards to ensure that competition and<br />
trade are not impeded.<br />
3. OBJECTIVES<br />
3.1 PRIMARY OBJECTIVE<br />
An objective of Government health and environment policy is to reduce the adverse<br />
effects of motor vehicle emissions on urban air quality, human health, and enhanced<br />
greenhouse effect. 3.2 SECONDARY OBJECTIVES<br />
The Government also has as objectives: a) the harmonisation of Australian vehicle<br />
emission standards with international standards; and b) the national availability of<br />
petrol and diesel of appropriate quality to allow the effective adoption of new<br />
vehicle engine and emission control technologies.<br />
These Government objectives are outlined in three policy statements: Safeguarding the<br />
Future: Australia’s Response to Climate Change(1997), Measures for a Better<br />
Environment (1999); and the Downstream Petroleum Products Action Agenda (1999).<br />
The Prime Minister’s 1997 statement, Safeguarding the Future: Australia’s Response to<br />
Climate Change sets out an Environmental Strategy for the Motor Vehicle Industry. The<br />
objective of the strategy is threefold - to enhance the environmental performance of the<br />
automotive industry; to reduce air pollution and improve the health of our cities; and to<br />
reduce greenhouse gas emissions. The adoption of new and emerging vehicle engine and<br />
emission control technologies is central to Government objectives with respect to the<br />
improved management of both noxious and greenhouse gas emissions.<br />
The Measures for a Better Environment package was announced by the Prime Minister in<br />
May 1999 as part of the New Tax System for Australia. It consists of a series of<br />
initiatives, many of them directed at the transport sector, to improve the management of<br />
noxious (air pollutant) and greenhouse gases. It establishes a timetable for the<br />
introduction of internationally harmonised vehicle emission standards and foreshadows<br />
changes to the composition of transport fuel. Diesel specifications identified in Measures<br />
for a Better Environment include a minimum standard of 500ppm sulfur in road transport<br />
fuel from the end of 2002 and the introduction of a "mandatory fuel standard of 50ppm<br />
(through a NEPM, equivalent legislative device or by use of the definition in the diesel<br />
fuel credit scheme) in 2006". It also noted the requirement for high octane and low sulfur<br />
levels in petrol. High-octane petrol enables higher thermal efficiencies to be achieved,<br />
while low sulfur content is essential for the deployment of advanced fuel efficiency<br />
technologies, such as direct injection, both of which help achieve reduced fuel<br />
consumption.<br />
The Measures for a Better Environmentpackage also introduced the Alternative <strong>Fuel</strong>s<br />
Conversion Program designed to facilitate the conversion or purchase of heavier<br />
commercial vehicles and buses operating on compressed natural gas (CNG) and liquified<br />
petroleum gas (LPG); and the Diesel and Alternative <strong>Fuel</strong>s (Grants) Scheme designed to<br />
maintain the relative equivalence of diesel and alternative fuel prices after July 2000.<br />
While the alternative fuels program does not relate directly to measures designed to
enhance the quality of conventional fuels, they are clearly associated with Option 5 of<br />
this statement, which is based on a wider use of alternative fuels.<br />
The Downstream Petroleum Products Action Agenda was released in November 1999.<br />
The Agenda identifies the Government’s strong preference for the development of<br />
nationally consistent fuel specifications, noting that there are "clear competition benefits<br />
from having a nationally consistent approach to fuel standards". It also advises that the<br />
Government will ensure that fuel specifications apply and are enforced equally to imports<br />
and domestically produced fuels.<br />
4 ANALYSIS OF OPTIONS<br />
This section outlines the seven potential options for reducing vehicle emissions, and<br />
improving the quality of petrol and diesel fuel in Australia;<br />
Option 1 - Business as Usual<br />
Option 2 - Industry Agreements Option 3 - State <strong>Regulation</strong><br />
Option 4 - <strong>National</strong> Environment Protection Measure<br />
Option 5 - Wider use of Alternative <strong>Fuel</strong>s<br />
Option 6 - Limiting Vehicle Travel<br />
Option 7 - Commonwealth <strong>Regulation</strong><br />
Each option has been evaluated using the following criteria:<br />
* provision of a nationally consistent approach to fuel quality standards;<br />
* consistency with preceding Government policy decisions on this matter;<br />
* assurance that appropriate fuel is available in line with the timetable for the<br />
implementation of new vehicle emission standards ADRs; and<br />
* no restriction on competition and trade.<br />
4.1 BUSINESS AS USUAL (Option 1)<br />
<strong>Fuel</strong> quality in Australia is currently largely unregulated. The introduction of unleaded<br />
petrol in 1985 (to support the introduction of new emission control technology needed to<br />
meet the emission standards specified in ADR 37/00) saw the majority of States and<br />
Territories introduce limited regulations addressing petrol composition in terms of lead<br />
content.<br />
<strong>Fuel</strong> standards have, however, been developed for diesel and petrol by <strong>Standards</strong><br />
Australia. They are AS 3570 - Automotive Diesel, and AS 1876 - Petrol. These<br />
‘standards’ have no legislative basis, but are rather industry guidelines whose main<br />
purpose is to specify compositional requirements that are consistent with engine<br />
development and reliable vehicle operation. As such, they cannot be considered to
address environmental issues (ie the reduction of harmful emissions from the use of the<br />
fuel) except indirectly. The Australian <strong>Standards</strong> address a number of fuel properties not<br />
generally considered significant in terms of emissions management, while omitting others<br />
known to be significant in this respect. In addition, these standards do not deal adequately<br />
with fuel specifications required for the deployment of advanced engine and vehicle<br />
technologies that would facilitate the delivery of reduced fuel consumption by vehicles.<br />
4.1.1 Advantages and disadvantages<br />
The current system does not provide for national consistency in terms of fuel<br />
composition. The actual properties of petrol and diesel fuel produced by each Australian<br />
refinery differ between refineries and, to a variable extent, from the specifications in the<br />
Australian <strong>Standards</strong> (Appendix 1). Little information is available on the quality of<br />
imported fuel.<br />
In 1998, Environment Australia commissioned Coffey Geosciences Pty Ltd to undertake<br />
a Review of <strong>Fuel</strong> <strong>Quality</strong> Requirements for Australian Transport to inform the process<br />
for developing fuel quality standards. The Review modelled the air quality outcomes (in<br />
terms of emissions reductions) from a range of scenarios, including a Business as Usual<br />
(BaU) option. It found that there would be substantial improvements in air quality over<br />
time from harmonisation with European fuel standards. For some pollutants, reductions<br />
of up to 60% in emissions are predicted over the BaU option for the period 2000 to 2020.<br />
Modelling results showed clear differences in emissions reductions over time from the<br />
vehicle fleet between BaU (Scenario 1) and increasing compliance with Euro fuel quality<br />
standards (Scenarios 2-6).<br />
For example, under the BaU scenario, emissions of fine particulate matter are estimated<br />
to decrease by 10% as the current ADRs take effect, and then to increase again from 2010<br />
as diesel vehicle use grows. In relation to oxides of nitrogen, the projected improvement<br />
in emissions under BaU is estimated as a 17% reduction between 2000 and 2010 as the<br />
ADRs take effect, while compliance with Euro standards gives estimated reductions of<br />
approximately 34% for the same period.<br />
The investment necessary on the part of the existing Australian refineries to meet tighter<br />
fuel specifications varies considerably, but is in all cases significant. The majority of the<br />
refineries, whose profit margins are already reduced due to the state of the global market,<br />
are unlikely to voluntarily undertake the investment necessary to produce low sulfur fuels<br />
within the timeframe set by the new vehicle emission standards ADRs.<br />
The announcement by the Commonwealth Government of the Measures for a Better<br />
Environmentinitiative, which foreshadowed changes to the sulfur content of petrol and<br />
diesel, has led to a number of States introducing or proposing to introduce State-specific<br />
fuel quality legislation. This has already taken place in Western Australia and<br />
Queensland. As noted earlier this appears likely to result in different standards in<br />
different jurisdictions. There are associated competition problems with this approach -<br />
raising effective barriers for refiners and importers to interstate markets and raising<br />
compliance costs.
Summary<br />
A business as usual approach will not provide for a nationally consistent approach to fuel<br />
quality standards. The lack of national standards would also result in Government policy<br />
decisions set out in the Measures for a Better Environment tax package not being<br />
implemented.<br />
Furthermore, the option does not guarantee that the appropriate fuel will be available in<br />
line with the timetable for the implementation of new ADRs, and the uptake of Statespecific<br />
legislation has the potential to restrict competition and trade across jurisdictions.<br />
INDUSTRY AGREEMENTS (Option 2)<br />
A Memorandum of Understanding (MoU) concerning the vapour pressure of petrol is<br />
currently in place between the NSW Government and NSW based refiners and importers.<br />
(The vapour pressure of petrol is an important element in controlling photochemical<br />
smog or ozone.) This arrangement appears to have operated satisfactorily, and to have<br />
been an important component of the local air quality management strategy.<br />
The Measures for a Better Environment initiative included a number of actions to<br />
promote the early introduction and use of low sulfur diesel before the introduction of<br />
mandatory standards. One of these measures was identified as "negotiation with the oil<br />
majors on the early voluntary introduction of diesel at 500 ppm in urban areas in 2000, on<br />
a best endeavours basis".<br />
It was proposed that this measure could be met through the development of a national<br />
MoU between the Commonwealth and State and Territory governments and domestic oil<br />
refiners and importers. Consultations with all stakeholders were undertaken and a draft<br />
MoU was prepared. After seeking legal advice, however, the oil majors advised that they<br />
were not able to enter into the proposed MoU due to potential competition problems. As a<br />
result a number of States proceeded to develop State-specific legislation.<br />
4.2.1 Advantages and disadvantages<br />
There is evidence that voluntary agreements between government and industry can be<br />
used to address specific air quality issues associated with fuel composition. It has,<br />
however, not been possible to adopt this approach on a national basis, and to expand it to<br />
cover a wide range of different fuel quality parameters, due to concerns on the part of the<br />
industry itself.<br />
Such agreements have substantial benefits in that industry effectively self-regulates -<br />
thereby reducing administrative and compliance costs. It is not possible, however, for the<br />
Commonwealth to guarantee fuel quality under such an arrangement. There are valid<br />
concerns on the part of vehicle manufacturers (and consumers) that there is no certainty<br />
that they will be able to obtain the quality of fuel required for the efficient operation of<br />
new generation vehicles. Emission control technologies can be permanently disabled<br />
through the use of fuel that does not meet specific compositional requirements. For<br />
example, sulfur content levels in both petrol and diesel are extremely significant in this<br />
respect.
There are also potential competition problems. These may arise when producers either<br />
decline to be party to such an agreement, or choose, on occasion, to operate outside the<br />
agreement with respect to one or more specific fuel parameters.<br />
The uncertainty inherent in such arrangements has prompted a number of States to<br />
consider State-specific legislation. As noted earlier in relation to Option 1 there are<br />
competition problems associated with this approach.<br />
Summary<br />
Voluntary agreements will not ensure a nationally consistent approach to fuel quality<br />
standards or the availability of appropriate fuel required for compliance with the new<br />
ADRs. As for Option 1, there are potential trade and competition problems associated<br />
with the approach.<br />
STATE AND TERRITORY REGULATION (Option 3)<br />
Almost all the States and Territories currently have some form of fuel quality regulatory<br />
regime. In the majority of cases this is currently limited to the lead content of petrol.<br />
However, the announcement by the Commonwealth of proposed fuel changes under the<br />
Measures for a Better Environment initiative has led to a number of States introducing or<br />
proposing to introduce State-specific fuel quality legislation.<br />
Queensland and Western Australia have already introduced such legislation, and South<br />
Australia has foreshadowed new legislation. Their proposals are outlined below.<br />
4.3.1 Queensland<br />
The Queensland Government gazetted new fuel quality regulations under the<br />
Environment Protection Act in July 2000. The regulations require Queensland oil refiners<br />
to produce fuel with the following specifications:<br />
* sulfur levels in diesel fuel to 500 ppm by from 15 July 2001 and remove lead from<br />
petrol by March 2001;<br />
* from 5 July 2000 maximum levels for MTBE, ETBE and TAME to be 0.5% by<br />
volume;<br />
* from 1 July 2000, the six monthly average benzene content of petrol to not exceed 3.5%<br />
by volume;<br />
* from 15 November 2000, maximum levels for Reid Vapour Pressure (RVP) (ranging<br />
from 78 kpa in 2000 to 69 kpa in 2002) for both fuel producers and wholesale distributors<br />
according to climate requirements.<br />
4.3.2 Western Australia<br />
<strong>Fuel</strong> quality specifications have been regulated in Western Australia from December<br />
1999, under the Environmental Protection (Diesel and Petrol) <strong>Regulation</strong>s 1999, as part<br />
of Western Australia’s Environment Protection Act 1986. The regulation specifies a
500ppm limit on the sulfur content of diesel from 1 January 2000. The following<br />
specifications (as maximum concentrations) have been set for petrol:<br />
Specifications for supplies in 2000 (maximum levels)<br />
Hydrocarbons:<br />
Aromatics 48.0% v/v<br />
Benzene 2.0% v/v<br />
Oxygenates:<br />
Methyl tertiary-butyl ether (MTBE) 0.10% v/v<br />
Lead: 13mg/L<br />
Specifications for supplies in 2002 (maximum levels)<br />
Hydrocarbons:<br />
Aromatics 42.0% v/v<br />
Benzene 1.0% v/v<br />
Olefins 18.0% v/v<br />
Oxygenates:<br />
Methyl tertiary-butyl ether (MTBE) 0.10% v/v<br />
Lead : 5mg/L<br />
Sulfur: 150 mg/kg.<br />
4.3.3 South Australia<br />
South Australia is currently developing State-specific legislation based on the US<br />
Predictive Model. The South Australian EPA advises that the proposed legislation will be<br />
based on a combination of the US EPA Predictive Model and California EPA cancer<br />
potency factors. They note that this approach enables a comparison of fuels based on air<br />
toxics performance. South Australia is using an outcomes based approach which involves<br />
generating the exhaust emissions (and some evaporative emissions, e.g. during refuelling)<br />
of certain toxic compounds and then calculating an ‘Air Toxics Index’ using potency<br />
factors from the California Air Resources Board for each of the compounds.<br />
While the South Australian Air Toxics Index is based on the Californian model it has<br />
been modified using the Port Stanvac refinery petrol as the base fuel for modelling. Some<br />
members of the refining industry have stated that the configuration of the Port Stanvac<br />
refinery is such that an Air Toxics Index based on its fuel could be very difficult for<br />
another refiner to meet.
South Australia suggests that the predictive model is more effective in addressing South<br />
Australia’s airshed issues. South Australia argues that the implementation of their<br />
standards via the predictive model is necessary to ensure that South Australian air quality<br />
is maintained. The South Australian model allows for adjustments, which they believe<br />
makes compliance easier.<br />
The proposed legislation is scheduled to come into effect in the second half of 2000.<br />
4.3.4 Advantages and disadvantages<br />
State-specific legislation has the potential to result in different standards for each<br />
jurisdiction. This may give rise to competition issues, by creating barriers for refiners and<br />
importers to interstate markets and raising compliance costs.<br />
There are clear competition benefits from having a nationally consistent approach to fuel<br />
standards. If a State’s specifications are unique and align with the production capability of<br />
local refiners, such local refiner(s) will obtain a degree of protection, as any trans-shipped<br />
cargoes from other States, or imported cargoes, will need to be produced specially for the<br />
unique State-specifications, and this is likely to be expensive.<br />
Furthermore, not all States may regulate fuel quality which would have implications for<br />
vehicle technology for cross-border traffic. <strong>Fuel</strong> of an appropriate quality needs to be<br />
available in all States and Territories to ensure adequate supply of the low sulphur and<br />
high octane fuels required for advanced emissions control technology.<br />
There is also a requirement to ensure equal protection for all Australians from toxic<br />
emission from the transport sector. If one State does not implement fuel quality<br />
standards, it could become a dumping ground for lower quality fuel and experience<br />
considerable increases in emissions and air pollution.<br />
Summary<br />
The use of State regulations will not provide for a nationally consistent approach to fuel<br />
quality standards. The outcome of such an approach would also result in Government<br />
policy decisions set out in the Measures for a Better Environment tax package not being<br />
implemented.<br />
The use of State-specific regulations will not ensure the nationwide availability of fuel<br />
quality required to enable the introduction of new ADRs, and State-specific regulations<br />
will also potentially restrict competition and trade.<br />
4.4 NATIONAL ENVIRONMENT PROTECTION MEASURE (Option 4)<br />
The <strong>National</strong> Environment Protection Council (NEPC) is empowered, on the basis of a<br />
two thirds majority vote by its members, to make national environment protection<br />
measures (NEPMs) that automatically become law within each State and Territory in<br />
accordance with the legal framework of each jurisdiction. The objectives of the <strong>National</strong><br />
Environment Protection Council Act 1994 are to provide equivalent environmental
protection to all Australians wherever they live and to ensure that markets are not<br />
distorted by environmental decisions.<br />
The efficiency of the current NEPM development and implementation processes are<br />
being reviewed and a major review of the NEPC Act, which is scheduled to commence in<br />
late 2000, will consider the effectiveness of NEPMs as a national approach to achieving<br />
environmental objectives.<br />
It is important to note that NEPMs are a costly and time consuming process. A NEPM<br />
may take approximately 2 years to develop and a further 2-3 years to implement, and the<br />
development process is likely to cost in total, including jurisdictional costs, in the order<br />
of $1 million or more. The resources required to develop and implement NEPMs has<br />
been a particular issue of concern for States and Territories and presents a possible barrier<br />
for their participation in the development process and particularly the implementation of<br />
NEPMs, especially for the smaller jurisdictions like Tasmania and the Northern Territory.<br />
The Council can develop and make a NEPM but implementation is outside the Council’s<br />
jurisdiction under the Act and is achieved through State and Territory legislation. It is<br />
apparent from those NEPMs that have already been developed that States can seek and<br />
achieve exemptions based on regional environmental differences. A good example of this<br />
is the exemption in the Queensland legislation of Mt Isa from the Ambient Air <strong>Quality</strong><br />
NEPM. There also tends to be a "lowest common denominator approach" to the<br />
development of NEPMs and resulting "national" standards, in an attempt to try and gain<br />
consensus from all jurisdictions.<br />
4.4.1 Advantages and Disadvantages<br />
While NEPMs have been effective in implementing other policies, a NEPM for national<br />
fuel quality standards is not a viable option for several reasons.<br />
In terms of NEPM development, a State or Territory may achieve exemptions based on<br />
regional environmental differences, and may also cease to be a participating member of<br />
the Council at any stage. Such actions would limit the ability to implement nationally<br />
consistent standards, particularly as each jurisdiction not only varies considerably in its<br />
capacity to meet tighter standards, but also in the levels of investment required by<br />
industry to upgrade plants in order to produce cleaner fuels.<br />
In terms of timeframes, the time line specified by Measures for a Better Environment<br />
would not be achieved in light of the time required for the NEPM development process.<br />
The development of a NEPM is considered a lengthy process and State processes for<br />
obtaining whole-of-government positions and approvals have the potential to delay the<br />
process further.<br />
With respect to the actual standards set, if States and Territories have divergent views<br />
then it would be difficult to form a consensus on national standards under a NEPM as<br />
only a two-thirds majority vote is required to pass the Measure.
Summary<br />
A NEPM for national fuel quality standards is not considered a viable option to ensure<br />
that nationally consistent standards are in place in the required timeline for the<br />
introduction of the new Australian Design Rules (ADRs) for motor vehicle emissions.<br />
Following the NEPM path would significantly delay the process and provide no real<br />
assurance that States would not provide exemptions in their legislation based on regional<br />
environmental differences. This approach may produce an outcome which is inconsistent<br />
with preceding Government policy decisions, and competition and trade will be restricted<br />
if variation in standards occurs between jurisdictions.<br />
4.5 WIDER USE OF ALTERNATIVE FUELS (Option 5)<br />
Alternative fuels provide an opportunity for reducing emissions of greenhouse gases and<br />
air pollutants by altering the mix of exhaust gases. The promotion of alternative fuels<br />
may have environmental benefits, but a focus on the adoption of such fuel does not<br />
address the current and future ADRs, which will remain highly dependent on petrol and<br />
diesel fuel.<br />
Furthermore, there is a finite, although increasing, capacity to run more of the fleet which<br />
currently use petrol and diesel fuel on alternative fuels. The most significant options are<br />
liquefied petroleum gas (LPG) and compressed natural gas (CNG).<br />
LPG is already widely used in urban areas, particularly by high mileage vehicles such as<br />
taxis, and its application to date is mainly in vehicle types normally configured for petrol<br />
fuels. Recent testing on modern petrol-engined vehicles, and equivalent vehicles running<br />
on LPG, concluded that the LPG-fuelled vehicles do not offer significant environmental<br />
benefits over the petrol-engined vehicles (FORS, 1997). Recent work in the UK and<br />
Europe indicates however, that heavy duty vehicles designed to run on LPG can have a<br />
very good emissions performance compared to diesel (Le Cornu and Day, 1998).<br />
Other evidence, such as the Australian Greenhouse Office’s (AGO) preliminary<br />
alternative fuels life-cycle analysis indicates that LPG performs well in heavier vehicles<br />
in respect of a number of greenhouse and other vehicular emissions.<br />
CNG has very limited use at the moment, and its greatest potential would appear to be as<br />
a diesel substitute in commercial vehicles operating out of a common refuelling point.<br />
The use of CNG is becoming more common in urban bus fleets (in Perth, Adelaide,<br />
Sydney and Brisbane for example). As a substitute for diesel fuel, it offers significant<br />
benefits in reductions of PM emissions over diesel engines but, according to BTCE,<br />
unless engine settings and emissions controls are adequate, NOx emissions +from CNG<br />
fuelled vehicles may be higher (BTCE, 1994). In contrast, the AGO’s life-cycle analysis<br />
found that CNG delivered a very good performance in respect of NOx provided vehicles<br />
are adequately maintained and their performance monitored. However, the very limited<br />
nature of the CNG vehicle refuelling network is a major barrier to wider adoption. The<br />
bulkiness of CNG fuel tanks and high capital cost for conversions can also limit its<br />
appeal to transport operators. These factors are being addressed through the<br />
Commonwealth’s alternative fuels program.
4.5.1 Advantages and Disadvantages<br />
The uptake of LPG and CNG is largely limited to urban areas, particular engine types and<br />
vehicle fleets. As outlined above, there are a number of major logistical barriers to the<br />
wider adoption of alternative fuels, and as such, alternative fuels are not considered a<br />
viable options (at this stage) to achieve the objectives in the required timeframe.<br />
The Commonwealth Government currently exempts both LPG and CNG from fuel excise<br />
as a means of encouraging their development as alternative fuels. The Government is not<br />
able to mandate the use of specific fuels, as it would be contrary to competition<br />
principles. As indicated above, the alternative fuels network has a limited capacity to<br />
supply the fleet, and thus the use of alternative fuels, in itself, is not sufficient to deliver<br />
significant reductions in total emissions from the road vehicle fleet.<br />
Summary<br />
The increased use of alternative fuels has the potential to reduce emission from motor<br />
vehicles. The Government has in place a number of policy options to encourage the use<br />
of alternative fuels, such as the CNG Infrastructure Program, the Alternative <strong>Fuel</strong>s<br />
Conversion Program, the Diesel and the Alternative <strong>Fuel</strong> Grants Scheme (which<br />
maintains the relative price of LPG and CNG compared to diesel), and the favourable<br />
excise treatment of LPG and CNG.<br />
However, the current capacity for switching to alternative fuels is limited, and their<br />
consideration as an option to achieve a national approach for fuel quality standards is not<br />
practicable at this stage. Should a significant transition to alternative fuels be achieved in<br />
the future (as the Commonwealth’s alternative fuels program seeks to achieve), then<br />
alternative fuels use will have a greater impact on improved environmental outcomes.<br />
Alternative fuels will probably have a neutral or positive impact on competition and<br />
trade. However, the relatively limited current penetration of alternative fuels in the<br />
Australian market means that at present they have limited value in addressing<br />
environmental concerns.<br />
While the proposed national fuel quality standards focus on petrol and diesel, it is<br />
envisaged that standards for alternative fuels would be considered for inclusion at a<br />
future date under the proposed framework legislation.<br />
4.6 LIMITING VEHICLE TRAVEL (Option 6)<br />
In order to address transport sourced urban air pollution and greenhouse emissions, there<br />
is ultimately a need to deal with the underlying issue of increasing vehicle travel,<br />
particularly as the emission and fuel consumption reductions achievable from<br />
technological improvements to vehicles and fuels become progressively smaller.<br />
Mechanisms to limit vehicle use include fiscal policies (to reflect true costs of transport),<br />
transport planning, traffic management (Auto-Oil, 1995) and travel demand management.
4.6.1 Advantages and Disadvantages<br />
Management mechanisms to limit vehicle travel are more relevant for transport<br />
emissions, rather than fuel quality per se. While these mechanisms will have an important<br />
place in stabilising and reducing transport air emissions, they are beyond the scope of the<br />
objectives specified for this <strong>Statement</strong>.<br />
Summary<br />
Mechanisms to limit vehicle travel are not directly related to fuel quality. They do not<br />
ensure the fuel quality auto manufacturers require to meet ADRs on emission standards<br />
and improve fuel efficiency of vehicles, and are therefore unable to meet the assessment<br />
criteria outlined at the beginning of this section.<br />
4.7 COMMONWEALTH REGULATION (Option 7)<br />
Commonwealth legislation will provide the framework for a national fuel standards<br />
regime with the levels for each of the parameters in petrol and diesel set in regulations<br />
under the Act. It is proposed, subject to any time constraints, that the framework<br />
legislation will be in place by the end of 2000.<br />
The primary legislation will also enable standards to be set for other fuels to be specified<br />
by regulation in the future (e.g. alternative road transport fuels such as LPG, biodiesel, or<br />
marine and aviation fuels), if this becomes a priority for the Government.<br />
The primary legislation will contain the following elements:<br />
a) a regulation making power to permit setting standards for fuels;<br />
b) provisions creating offences relating to the supply of fuel that does not meet standards<br />
specified in the regulations;<br />
c) monitoring and enforcement provisions, setting out record keeping and reporting<br />
requirements imposed on suppliers and providing authority for the Commonwealth to<br />
sample, monitor and enforce the fuel quality requirements; and<br />
d) administrative arrangements for granting of exemptions from the standards where this<br />
is in the public interest or in specified circumstances, for example to meet the<br />
requirement of different climatic conditions.<br />
The legislation will apply equally to fuel importers and domestic refiners. It will regulate<br />
the quality of fuel along the entire chain of supply, so that importers, domestic producers,<br />
distributors, wholesalers and retailers will be held accountable for fuel quality under the<br />
Act.<br />
The intention of the legislation is not to dictate the composition of fuel, but rather to<br />
establish standards for certain fuel parameters. The regulations will specify, for each fuel<br />
type, the level at which a particular fuel parameter, for example sulfur content, will be set<br />
and the timeframe by which the parameter standard must be met.
The Commonwealth proposal for fuel standards sets out a timeframe including the<br />
following key dates:<br />
* for diesel<br />
- harmonisation with Euro 2/3 diesel fuel specifications by 1 January 2002 ; and<br />
- harmonisation with Euro 4 diesel fuel specifications before 1 January 2006.<br />
* for petrol<br />
- harmonisation with Euro 2 petrol specifications (Euro 3 for sulfur content) by 1 January<br />
2002;<br />
- harmonisation with Euro 3 petrol specifications by 1 January 2005 (Euro 4 for sulfur<br />
content); and<br />
- harmonisation with Euro 4 petrol specifications by 1 January 2008/2010.<br />
These dates are based on the timeframe for the introduction of new United Nations<br />
Economic Commission for Europe ("Euro") vehicle emissions standards as specified in<br />
the new ADRs gazetted in 1999. They are intended to ensure that the required fuel is<br />
available for the introduction of the ADRs and that sufficient lead-time is available to<br />
refiners to make the necessary investment to produce the fuels.<br />
Summary<br />
The introduction of Commonwealth legislation would provide the national consistency<br />
necessary for the introduction of fuel quality standards to avoid competition problems<br />
and ensure that fuel of the appropriate quality is widely available in Australia in line with<br />
the timetable for the introduction of the new emissions control technology. The<br />
introduction of the legislation is also in line with preceding Government policy decisions<br />
on fuel quality.<br />
4.8 COMPARATIVE ASSESSMENT<br />
Commonwealth legislation is the only option which satisfies all of the specified<br />
assessment criteria, that is, it<br />
1. provides a nationally consistent approach to fuel quality standards;<br />
2. is consistent with preceding Government policy ;<br />
3. can ensure that appropriate fuel is available in line with the timetable for the<br />
implementation of new ADRs; and<br />
4. does not restrict competition and trade.<br />
Appendix 2 summarises the effectiveness of each option against the selection criteria.<br />
Options 6 and 7 on wider use of alternative fuels and limiting vehicle travel have not
een included as they are not considered viable options at this stage to achieve the<br />
objectives in the required timeframe.<br />
5. IMPACT (COSTS AND BENEFITS) OF PREFERRED OPTION<br />
This assessment of the costs and benefits of the preferred option addresses the impact of<br />
the framework legislation proposed for regulating national fuel quality standards.<br />
<strong>Regulation</strong>s specifying the actual standards for various fuel parameters will be developed<br />
under the framework legislation later in 2000. A separate <strong>Regulation</strong> <strong>Impact</strong> <strong>Statement</strong><br />
will address the regulations.<br />
A Commonwealth proposal for the fuel parameter standards was outlined in three<br />
discussion papers released in May 2000 for a two-month public comment period. In the<br />
absence of a final recommendation for fuel quality standards, this proposal is used as the<br />
basis for estimating the costs and benefits of the preferred option.<br />
This section briefly recounts the preferred option, summarises and outlines the costs and<br />
benefits of the option and addresses the impacts on affected parties.<br />
5.1 OUTLINE OF THE PREFERRED OPTION<br />
The preferred option is to set national fuel quality standards by means of Commonwealth<br />
regulation. The legislation will provide the framework for a national standards regime<br />
with the levels for each of the parameters in petrol and diesel specified in regulations<br />
under the Act.<br />
As described in section 4.7, national fuel quality standards will:<br />
- apply equally to importers and domestic refiners;<br />
- introduce from 2002 the fuel quality standards required by vehicles complying with the<br />
new ADRs (see timetable under section 5.5.2);<br />
- be monitored and enforced along the fuel chain of supply;<br />
- be consistent across the nation, allowing exceptions in specified circumstances, for<br />
example to meet varying climatic conditions.<br />
5.2 SUMMARY OF ASSESSMENT<br />
In summary, the analysis of costs and benefits found that there would be considerable<br />
health and environmental benefits from moving to cleaner fuel standards, with an overall<br />
net benefit to Australia. The analysis estimated the net health benefits from the<br />
introduction of high fuel standards to be between $1577M and $2180M. This assessment<br />
is not altered by the potential macroeconomic impact of higher fuel prices, which would<br />
only be transitory before market forces re-balance the impacts.<br />
The analysis is outlined in the Table 5.1 below. Option D corresponds to the fuel<br />
standards and timetable proposed for discussion by the Commonwealth.
Table 5.1: Net Benefits of adopting higher fuel standards (NPV $ million 1999)<br />
OPTION A B C D<br />
Petrol (Cars)<br />
Diesel (Trucks)<br />
COSTS<br />
NSW EPA estimates<br />
Euro 2 in<br />
2002<br />
Euro 2 in<br />
2002<br />
Euro 2 in<br />
2002<br />
Euro 3 in<br />
2005<br />
Euro 3 in<br />
2002<br />
Euro 3 in<br />
2002<br />
Euro 3 in<br />
2002<br />
Technology and hardware 662 810 807 na<br />
<strong>Fuel</strong> reformulation 1,084 1,287 na<br />
Certification 70 70 70 na<br />
Review estimates<br />
Capital and operating costs na 848 na<br />
Total costs 732 848 - 1,964 2,164<br />
AIR QUALITY BENEFITS<br />
(avoided health costs)<br />
Euro 3 in<br />
2005<br />
Euro 4 in<br />
2008<br />
Euro 3 in<br />
2002<br />
Euro 4 in<br />
2006<br />
1,230 -<br />
1,833<br />
1,230 -<br />
1,833<br />
Hydrocarbons 80 630 892 > 849<br />
Nitrogen dioxide 409 1,071 1,409 > 1,361<br />
Carbon monoxide 38 217 341 > 318<br />
Particulates 324 884 882 > 882
Total benefits 851 2,802 3,524 > 3,410<br />
Benefit/Cost ratio 1.16 1.41 - 3.26 1.63<br />
NET BENEFITS 119 798 - 1,914 1,359<br />
>1.86 -<br />
>2.77<br />
1,577 -<br />
2,180<br />
Notes: Adapted from NSW EPA (1999) and Review Report (2000). Option A based on<br />
EPA scenario 1, Option B based on EPA scenario 5 and Review Scenario 2, Option C<br />
based on EPA scenario 3, Option D based on Review Scenarios 3 and 4 with benefit<br />
estimates based on EPA scenarios 3 and 5. All figures in Present Values discounted at 7%<br />
over 20 years. Figures may not add due to rounding.<br />
5.3 COSTS OF THE PREFERRED OPTION<br />
The costs of implementing national fuel quality standards under Commonwealth<br />
regulation are borne mainly by the refining industry and consumers. <strong>Impact</strong>s on all<br />
parties are outlined in greater detail below.<br />
The Review of <strong>Fuel</strong> <strong>Quality</strong> Requirements for Australian Transport March 2000 (known<br />
as the <strong>Fuel</strong> <strong>Quality</strong> Review) commissioned by Environment Australia and undertaken by<br />
Coffey Geosciences Pty Ltd provides the best available estimate of the costs of the<br />
proposed new fuel standards to the refining industry. However, as outlined in Section<br />
5.5.2, due to the differences between the Commonwealth proposal and the scenarios<br />
analysed in the <strong>Fuel</strong> <strong>Quality</strong> Review, the costs are likely to be overestimated. The cost of<br />
Option D given in Table 5.1 is overestimated because it includes investment already<br />
made by one refiner. It is envisaged that the fuel quality standards for petrol and diesel<br />
will fall somewhere between the levels modelled under scenarios 3 and 4 of the <strong>Fuel</strong><br />
<strong>Quality</strong> Review - not full harmonisation with Euro 4 fuel standards as estimated below.<br />
The Review estimated that costs to the refining industry of full harmonisation with Euro<br />
4 fuel standards would be:<br />
- $1320 million (M) in capital investment over the period to 2008 ($185M on average per<br />
refinery); and<br />
- $136M pa in operating costs, an average of $17M pa per refinery from 2005.<br />
These estimates equate to column D of Table 5.1 but have not been discounted to<br />
incorporate Net Present Values as presented in the Table.<br />
Allowing a capital charge at 20% per annum, the average extra capital plus operating<br />
costs for local refining of Euro 4 fuels would be 1.5c/l for Euro 4 diesel and 1.1c/l for<br />
Euro 4 petrol. Under the Commonwealth proposal, Euro 4 diesel would be produced from<br />
2005/6 and full specification Euro 4 petrol would be produced, at the earliest, from 2008.
It is probable that these increased costs of production would be passed on to consumers<br />
as increased fuel prices. It is expected that any fuel price changes would be experienced<br />
in the 2005 to 2008 period, given the proposed tighter sulfur specifications from 2005.<br />
Economic analysis conducted as part of the <strong>Fuel</strong> <strong>Quality</strong> Review, using a General<br />
Equilibrium Model, estimated that a 1% increase in fuel prices would cause minor<br />
economic impacts such as an increase in the Consumer Price Index (less than 0.02%) and<br />
a fall in real wages (0.08%). It should be noted that this level of price increase currently<br />
occurs under fluctuating fuel prices caused by changes in the cost of crude oil.<br />
5.4 BENEFITS OF THE PREFERRED OPTION<br />
The benefits of Commonwealth regulation to implement national fuel quality standards<br />
flow from avoided health costs occasioned by improvements in urban air quality resulting<br />
from reduced pollutant emissions. Although difficult to quantify, the flow on benefits<br />
would include reduced greenhouse gas emissions over the longer term.<br />
It is estimated that from 2000 to 2019, avoided health costs will amount greater than<br />
$3,410M. The analysis does not include other benefits such as investment opportunities,<br />
visual amenity, export potential, or avoided infrastructure damage. The inclusion of<br />
estimates for these effects would increase the overall benefits.<br />
This assessment is based on work performed by the NSW Environment Protection<br />
Agency, which formed the basis of the <strong>Regulation</strong> <strong>Impact</strong> <strong>Statement</strong> on New Australian<br />
Design Rules for Control of Vehicle Emissions, December 1999. The NSW EPA work<br />
draws on a number of Australian and overseas studies including the Victorian Transport<br />
Externalities Study conducted by the Victorian EPA and the Bureau of Transport and<br />
Communications Economics, the <strong>National</strong> Environment Protection Measure on Ambient<br />
Air <strong>Quality</strong>, and assessments by the World Health Organisation and the US Environment<br />
Protection Authority.<br />
The benefit estimates associated with the NSW EPA data were gained through the use of<br />
the dose-response technique. This approach examines the relationship between an<br />
increase in one or more pollutants and the number of individuals in the population who<br />
are affected, and the severity of this impact. A monetary value of this physical impact is<br />
then estimated with reference to data on the cost of medical treatment and the cost to<br />
employers of lost worker productivity through illness and associated lost working time.<br />
Australian cost data are used where possible, with international studies used for<br />
comparisons and to provide the dose-response functions for some pollutants.<br />
Air pollutant emissions<br />
The <strong>Fuel</strong> <strong>Quality</strong> Review found that there would be substantial reductions in pollutant<br />
emissions following harmonisation with European emissions and fuel standards (Euro 3<br />
and then Euro 4). For some pollutants, reductions of up to 60% in emissions were<br />
predicted over a 20-year period from 2000.
Table 5.2 gives the estimated reduction in emissions over time for the major pollutants of<br />
concern under Scenario 4 modelled in the <strong>Fuel</strong> <strong>Quality</strong> Review, which has been taken as<br />
the indicator of the costs of implementing the Commonwealth proposal.<br />
Table 5.2: Reductions in emissions under Scenario 4<br />
Pollutant<br />
Emissions Reduction %<br />
2000 - 2010<br />
Hydrocarbons 20 - 25 29<br />
Oxides of Nitrogen 34 69<br />
Particulate Matter (PM10) 25 33<br />
Benzene 51 72<br />
Carbon Monoxide 45-51 66<br />
Greenhouse gas emissions<br />
Emissions Reduction %<br />
2000 - 2020<br />
The <strong>Fuel</strong> <strong>Quality</strong> Review assessed changes to transport-sourced greenhouse emissions<br />
and changes to greenhouse emissions from more intensive refining operations.<br />
Greenhouse gas emissions over the long term are expected to be lower as a result of<br />
improved fuel quality specifications associated with national fuel quality standards,<br />
relative to the business-as-usual scenario.<br />
Emissions from road transport are estimated to increase by 24% under business as usual<br />
(Scenario 1) for the period 2000 to 2010, and by only 15% over the same period for the<br />
other scenarios (Scenarios 2-6). The 9% improvement in the latter estimate is predicated<br />
on the assumption that the Government expectation of 15% improvement over businessas-usual<br />
<strong>National</strong> Average <strong>Fuel</strong> Consumption (NAFC) target would be achieved in 2010.<br />
Setting and achieving a challenging NAFC target in 2010 forms part of the<br />
Environmental Strategy for the Motor Vehicle Industry, which was announced in the<br />
Prime Minister’s 1997 statement Safeguarding the Future.<br />
Improved fuel parameters will help achieve improved fuel efficiencies, which would<br />
facilitate setting and achieving better NAFC targets. This in turn will translate to<br />
greenhouse benefits. The fuel parameters key to better fuel efficiencies are high-octane<br />
petrol, which enables higher thermal efficiencies to be achieved, and low sulfur content,<br />
which is essential for the deployment of advanced fuel efficiency technologies, such as
direct injection. It is claimed that direct injection technology is capable of improving fuel<br />
consumption by about 10%. Improved fuel quality in respect of other parameters would<br />
also promote optimal engine performance, thereby contributing to better fuel efficiencies.<br />
Legislated fuel quality enhancements would provide the certainty required for the<br />
deployment of advanced engine and vehicle technologies by automotive manufacturers<br />
and its uptake by consumers.<br />
In the case of emissions changes from refinery operations, an assessment of incremental<br />
refinery emissions suggested increased greenhouse emissions associated with the<br />
production of improved fuel quality. Increased energy consumption will result from<br />
direct fuel burning in process furnaces, carbon rejection to make hydrogen and by remote<br />
electricity generation. Although emissions by refiners are expected to increase (around<br />
2.1 million tonnes per annum CO2 equivalent) in association with the production of<br />
improved fuel quality, these are expected to be offset by lower emissions in road<br />
transport. Lower emissions are expected to continue over the longer term beyond 2010.<br />
5.5 IDENTIFICATION OF AFFECTED PARTIES<br />
The parties that will be affected by the introduction of Commonwealth legislation<br />
regulating fuel quality standards are:<br />
* state/territory government agencies; * refining industry; * fuel importers and<br />
distributors; * fuel retailers;<br />
* automotive industry; and * consumers.<br />
An assessment of the potential impact on each party is provided below, based on the fuel<br />
specifications proposed for discussion by the Commonwealth in Setting <strong>National</strong> <strong>Fuel</strong><br />
<strong>Quality</strong> <strong>Standards</strong> Paper 2: Proposed <strong>Standards</strong> for <strong>Fuel</strong> Parameters. The actual impact<br />
on each of the parties will depend on the final set of fuel standards specified in the<br />
regulations under the proposed legislation. A summary of the impacts is provided in<br />
Appendix 3.<br />
5.5.1 IMPACT ON STATE/TERRITORY GOVERNMENT AGENCIES<br />
Jurisdictions have indicated in principle support towards a national approach to fuel<br />
quality. A key concern for State and Territory Government agencies is the proposal that<br />
Commonwealth legislation for national fuel quality standards will override State-specific<br />
legislation on fuel quality. As outlined under section 4.3, Western Australia, Queensland<br />
and South Australia are implementing their own fuel quality legislation.<br />
Some States have indicated that they do not want to see a worse environmental outcome<br />
in their airsheds as a result of Commonwealth standards that are less stringent than those<br />
they have already imposed. Western Australia, for example, has regulated a level of 1%<br />
benzene from 2001, whereas the Commonwealth has proposed a level of 3% be<br />
introduced in 2002 and then 2% in 2005. However, levels of benzene in ambient air are<br />
generally not an issue in Australia where levels are below the limit recommended by the<br />
World Health Organisation ie 5 ppb.
As it is proposed that the Commonwealth fund enforcement and monitoring costs for<br />
national fuel quality standards, it is envisaged that these costs in the jurisdictions would<br />
be reduced once the Commonwealth legislation was introduced. States and Territories<br />
would no longer incur this expenditure for their State-specific standards and it is likely<br />
that the assistance provided by them for the Commonwealth process would be<br />
reimbursed.<br />
There is concern in the jurisdictions that Commonwealth standards will result in the<br />
closure of some refineries. The impact of tighter standards on the refining industry is<br />
discussed below.<br />
5.5.2 IMPACT ON THE REFINING INDUSTRY<br />
The Downstream Petroleum Action Agenda acknowledges that the Australian petroleum<br />
refinery industry is in crisis. As currently structured, its high costs make it internationally<br />
uncompetitive. The industry’s profitability is currently low and declining, having more<br />
than halved in recent years, and yet it urgently needs to be able to fund investment to<br />
meet the Government’s timetable for new fuel specifications. Significant restructuring<br />
and investment is also required to enable industry to compete with large scale, low cost<br />
refineries in Asia.<br />
The Action Agenda acknowledge that even though the industry currently faces many<br />
challenges, the oil industry is committed to improving air quality, particularly in<br />
Australian capital cities.<br />
Significant investment will be required by the refining industry to meet tighter fuel<br />
standards. Australia’s eight major refineries have different configurations as a result of<br />
different investment decisions and, therefore, different capacities to meet the fuel<br />
specifications. The major investment costs are associated with reducing the fuel sulfur<br />
content of diesel and the benzene content of petrol, and increasing the octane rating of<br />
petrol while reducing its aromatic content.<br />
The cost to the industry will vary depending on the timing of the introduction of the<br />
standards and the combination of parameter levels proposed. The final costs to industry<br />
will be known when the actual fuel standards are finalised later in 2000, and individual<br />
refinery strategies to meet the standards are decided.<br />
Depending on the final fuel standards implemented under Commonwealth regulation, and<br />
given the current world downturn in the refining industry, one or more refineries may<br />
contemplate closure. Shell has already announced that its Clyde refinery in NSW may<br />
close before 2006, when the production of Euro 4 diesel (with 50 ppm sulfur content)<br />
becomes mandatory. Shell is currently considering its position in the light of the<br />
Government’s proposed fuel standards.<br />
A comprehensive analysis of the potential costs to the refining industry of a number of<br />
fuel quality scenarios was undertaken by the <strong>Fuel</strong> <strong>Quality</strong> Review. The fuel quality<br />
standards proposed for discussion by the Commonwealth include a slightly different<br />
timetable for the introduction of Euro 3 and Euro 4 for some parameters, compared to
that modelled in the <strong>Fuel</strong> <strong>Quality</strong> Review. The comparison for those parameters requiring<br />
significant refinery investment is outlined in the Table 5.3 below.<br />
Table 5.3: <strong>Fuel</strong> parameters requiring significant refinery investment<br />
<strong>Fuel</strong> Parame<br />
ter<br />
Year of<br />
Introduction<br />
Commonwealth<br />
Proposal<br />
<strong>Fuel</strong> <strong>Quality</strong> Review<br />
Scenario 4<br />
Petrol Sulfur 2002 150 ppm 500 ppm (Euro 2)<br />
Diese<br />
l<br />
2005 50 ppm 150 ppm (Euro 3)<br />
2008 30 ppm* 50 ppm (Euro 4)<br />
Benzene 2002 3% Not specified<br />
Aromati<br />
cs<br />
2005 2% 1% (Euro 3)<br />
2002 45% Not specified<br />
2005 42% 42% (Euro 3)<br />
2008 38%* 35% (Euro 4#)<br />
Olefins 2002 18% Not specified<br />
Sulfur 2002<br />
2005 16% 18% (Euro3)<br />
2008 - 14% (Euro 4#)<br />
2005/6 50 ppm<br />
* These proposed standards are indicative only.<br />
500 ppm (From 1 January<br />
2002)<br />
500 ppm (By end 2002)<br />
50 ppm (From 1 January<br />
2006)
# Euro 4 for petrol has yet to be formally defined. These estimated levels were provided<br />
to Coffey Geosciences by the Australian Institute of Petroleum<br />
Despite differences to the Commonwealth proposed fuel standards, Scenario 4 from the<br />
<strong>Fuel</strong> <strong>Quality</strong> Review provides the best available estimate of the potential costs to the<br />
refining industry of Commonwealth regulation of national fuel standards. Some costs,<br />
particularly those associated with Euro 4 standards for olefins and aromatics (not<br />
included in the Commonwealth proposal) are overstated.<br />
The capital investment cost to refiners of achieving Euro 4 standards under Scenario 4 of<br />
the fuel <strong>Quality</strong> Review is $1320 million (M) above what is already planned. At one<br />
refinery, a substantial proportion of the investment required to achieve Euro 4 diesel and<br />
petrol is already committed in existing programs. Excluding this refiner, capital<br />
investment per refinery averages $185M.<br />
Under Scenario 4 operating expenditure would increase by a total of $136M pa for the<br />
production of Euro 4 fuels, an average of $17M pa per refinery.<br />
Allowing a capital charge at 20% per annum, the average extra capital plus operating<br />
costs for local refining of Euro 4 fuels would be:<br />
* Euro 4 Diesel 1.5 c/L<br />
* Euro 4 Petrol 1.1 c/L.<br />
The potential overstatement of costs due to levels of stringency not involved in the<br />
Commonwealth proposal include:<br />
* $100M capital expenditure and 0.2c/l to achieve 1% benzene compared to 3%; and<br />
* $170M capital expenditure and 0.9c/l operating costs at two refineries for achieving<br />
14% olefins compared to 16%.<br />
In addition, technological advances for refinery production processes may generate<br />
savings in the cost of production that may drive down any increase in the price of fuel.<br />
However, the actual impact on prices to consumers will be dependent on the companies’<br />
handling of any cost savings.<br />
5.5.3 IMPACT ON FUEL IMPORTERS AND DISTRIBUTORS<br />
Importers<br />
In order to ensure the availability of higher quality fuels for use in road transport<br />
throughout Australia, it is necessary to establish clear, attainable standards that do not<br />
discriminate between domestic fuel producers and importers. The national standards will,<br />
therefore, provide a level of consistency for importers, enabling them to supply the same<br />
fuel throughout the country.<br />
The impact on independents and importers (Burmah, Liberty Oil, Gull Petroleum,<br />
Woolworths Petrol Plus, etc) will vary depending on readily available supply in the
egion. It would appear that Euro 2 and 3 specifications are readily available or will be<br />
from 2001, but supply of Euro 4 at this point in time is restricted to export orientated<br />
refineries in India and South East Asia. Euro 4 will not be introduced into Europe until<br />
2005, when it is expected that this fuel will be more widely available.<br />
While higher quality fuels are in limited supply, the cost of obtaining them will be greater<br />
than that of sourcing fuel of the current quality sold in Australia. Information about the<br />
likely cost increases to importers is limited.<br />
Distributors<br />
Distributors purchase fuel from the major refining companies and, increasingly, from<br />
importers, and then transport it to regional service stations and fuel depots as well as<br />
primary producers and mining companies. There are currently about 200 large<br />
distributors that represent 40% of product distribution in Australia with 90% of this to<br />
regional areas.<br />
Commonwealth legislation regulating fuel quality will also provide national consistency<br />
for distributors. Consultation with the Australian Petroleum Agents and Distributors<br />
Association (APADA) has indicated that distributors are very supportive of the<br />
introduction of national standards. APADA pointed out that State boundaries are not<br />
observed in fuel distribution and some distributors traverse three States. State-specific<br />
legislation is, therefore, an issue of concern for distributors as it would increase their<br />
compliance costs.<br />
The main issue for distributors resulting from the introduction of Commonwealth fuel<br />
quality legislation would be the potential requirement for additional investment if extra<br />
storage tanks were needed to ensure any fuel mixing did not occur. This would be a<br />
requirement if the number of grades of fuel increased, but that is not envisaged in the<br />
Government’s proposal.<br />
5.5.4 IMPACT ON FUEL RETAILERS<br />
The impact on fuel retailers will relate mainly to ensuring that they receive only fuel that<br />
meets the specified standards, that any forecourt additives for sale have been approved<br />
under the legislation and that they keep the appropriate records and paperwork.<br />
Some of the small fuel retailers, particularly in rural and remote areas have limited or no<br />
storage and dispensing facilities for premium unleaded petrol (PULP). This could<br />
potentially cause some difficulties when PULP becomes the standard fuel. However, it is<br />
anticipated that the facilities used for leaded petrol may be replaced with PULP when<br />
leaded petrol is phased out in 2002.<br />
5.5.5 IMPACT ON THE AUTOMOTIVE INDUSTRY<br />
The most significant impact of Commonwealth fuel quality legislation on the automotive<br />
industry will be the certainty it provides in ensuring that fuel of the appropriate<br />
specifications will be widely available in Australia. This is essential to enable<br />
deployment of the advanced emissions control technology to meet tighter emissions
standards and advanced engine and vehicle technology to achieve improved fuel<br />
efficiency. The Federal Chamber of Automotive Industries (FCAI) is in favour of<br />
mandatory enforceable national fuel standards.<br />
An issue raised by the FCAI relates to the simultaneous availability of 91 RON and 95<br />
RON fuels. The industry is concerned about potential misfuelling of Euro 3 vehicles<br />
(designed for 95 RON fuel) with 91 RON fuel and resultant complaints from consumers<br />
should unsatisfactory engine performance result. However, little data is available on the<br />
likely rate of misfuelling. Some vehicle manufacturers detune their vehicles to run on 91<br />
RON fuel. Both misfuelling by consumers and detuning by manufacturers contribute to<br />
reductions in fuel efficiency and therefore increases in greenhouse gas emissions.<br />
5.5.6 IMPACT ON CONSUMERS<br />
As indicated in Section 5.5.2 above, the <strong>Fuel</strong> <strong>Quality</strong> Review estimated that the<br />
introduction of Euro 4 petrol by 2008 and Euro 4 diesel by 2006 would result in an<br />
increase in the cost of fuel production of 1.1c/l for petrol and 1.5c/l for diesel. It is<br />
probable that these costs would be passed on to consumers as increased fuel prices.<br />
However, for new vehicle owners, improved vehicle technology combined with high<br />
quality fuel will lower fuel consumption, leading to potential savings.<br />
Economic analysis conducted as part of the <strong>Fuel</strong> <strong>Quality</strong> Review, using a General<br />
Equilibrium Model, estimated that a 1% increase in fuel prices would cause minor<br />
economic impacts such as an increase in the Consumer Price Index (less than 0.02%) and<br />
a fall in real wages (0.08%). It should be noted though, that this level of price increase<br />
currently occurs under fluctuating fuel prices caused by changes in the cost of crude oil.<br />
Large populations of urban dwelling consumers will benefit from the reduction in<br />
pollutant emissions and resultant improvement in air quality outlined in Section 5.4.<br />
6. CONSULTATION<br />
The process for developing national fuel quality standards commenced with the <strong>Fuel</strong><br />
<strong>Quality</strong> Review. The final report from the Review was released in March 2000. Three<br />
discussion papers were then released in early May 2000 for a two-month public comment<br />
period with submissions requested by 30 June 2000. The papers present the<br />
Commonwealth’s proposal for fuel standards and are entitled:<br />
1. Summary Report of the Review of <strong>Fuel</strong> <strong>Quality</strong> Requirements for Australian<br />
Transport;<br />
2. Proposed <strong>Standards</strong> for <strong>Fuel</strong> Parameters (Petrol and Diesel); and<br />
3. Proposed Model for <strong>Standards</strong> Implementation.<br />
<strong>Fuel</strong> <strong>Quality</strong> Review<br />
In order to assess the potential impacts of new fuel quality specifications on all<br />
stakeholders, including Australian refineries, vehicle manufactures and consumers, and
taking into account the objectives of the regulators, it was necessary to obtain a high level<br />
of cooperation from stakeholders.<br />
During April and May 1999, the Review Team consulted with a broad range of<br />
stakeholders including many within government, the automotive industry and the<br />
petroleum industry, to solicit views on future fuel quality scenario development.<br />
The stakeholder consultation process commenced with the circulation of a letter to the<br />
stakeholders, informing them that a series of scenarios was to be developed to represent<br />
the range of likely changes in fuel quality over the next ten years. Comment was sought<br />
from the stakeholders regarding the key issues to be considered in the fuel quality<br />
scenarios.<br />
Written responses were received from 28 stakeholders. A Coffey representative also<br />
attended meetings with 30 of the major stakeholders, including State government<br />
agencies, petroleum companies and motor vehicle manufacturers. The stakeholder<br />
consultation process continued throughout 1999, with the stakeholders providing<br />
comment on the draft scenarios, particularly in relation to the incorporation of the Prime<br />
Minister’s commitments under the Measures for a Better Environment tax package<br />
agreement.<br />
The main issues identified by the stakeholders for consideration in the development of<br />
the scenarios included:<br />
* Air quality and the Ambient Air <strong>National</strong> Environment Protection Measure (NEPM).<br />
More stringent new vehicles emission standards were seen as an essential strategy to<br />
combat the detrimental air quality effects that would arise from projected growth in<br />
vehicle kilometres travelled and assist with achieving and maintaining compliance with<br />
the ambient air quality standards specified in the NEPM;<br />
* Greenhouse commitments. Stakeholders considered that improvements in vehicle fuel<br />
efficiency are important in helping to meet Australia’s commitment to the greenhouse gas<br />
emission targets set in the Kyoto Protocol;<br />
* Emissions standards harmonisation;<br />
* The government’s expectation of a 15% improvement over business-as-usual in the<br />
national average fuel consumption (NAFC) by 2010;<br />
* The increasing demand for high octane petrol following the introduction of more<br />
stringent emissions standards. Government agencies were concerned that this would put<br />
pressure on refiners to increase benzene, aromatics and olefins in order to achieve higher<br />
pool octane. Refiners were concerned that limits on these compounds would substantially<br />
increase the investment required to make higher octane petrol. The use of octane<br />
enhancement additives was also raised as an issue with potential impacts on the<br />
environment and fuel efficiency performance. The increase in greenhouse gas emissions<br />
from refineries through production of higher octane petrol was also seen as an important<br />
issue for consideration in the development of fuel quality scenarios;
* The possibility of supplying dual grade ‘city/country’ diesel, with low sulphur diesel<br />
supplied in the major city areas and higher sulphur diesel supplied in the country areas<br />
for an interim period; and<br />
* Incentives for the promotion of green fuels suitable for use in transport and switching<br />
of vehicles to such fuels.<br />
Commonwealth’s proposal for national fuel quality standards<br />
As part of the consultation process for developing national fuel quality standards, the<br />
Commonwealth held face to face meetings with stakeholders in the jurisdictions during<br />
May and June 2000. The main objective of these meetings was to provide an opportunity<br />
for stakeholders to discuss the proposals presented in the discussion papers and any<br />
issues of concern relating to the proposed standards or the process for implementing<br />
them.<br />
The Commonwealth team consisted of representatives from Environment Australia,<br />
Australian Greenhouse Office, Department of Industry, Science and Resources, and the<br />
Department of Transport and Regional Services. An Interdepartmental Committee<br />
representing other relevant Commonwealth Government departments was also consulted<br />
during development of the Commonwealth legislation and proposed fuel quality<br />
standards.<br />
The main issues arising from this consultation process include:<br />
* The proposal that Commonwealth legislation will override any inconsistent State<br />
regulations. Western Australia, Queensland and South Australia have introduced or will<br />
be introducing State-specific legislation where some standards, e.g. for benzene, are more<br />
stringent than the standard proposed by the Commonwealth. They have indicated quite<br />
strongly that they do not want to see Commonwealth standards result in a worse<br />
environmental outcome in their jurisdictions.<br />
* Concern has also been expressed that the timing for the introduction of fuel standards<br />
will close some refineries which would also have implications for dependent industries,<br />
e.g. the petrochemical industry.<br />
* The timing of the introduction of fuel standards to facilitate the new emissions control<br />
ADRs. The Commonwealth proposes introducing standards for technology enabling<br />
parameters 12 months in advance of the mandated date for the new ADRs. as specified<br />
under Measures for a Better Environment. The automotive industry has indicated that<br />
Euro 3 vehicles will be introduced during the 12 months leading up to the mandated date.<br />
It will, therefore, be necessary to ensure that appropriate fuel is available during this lead<br />
up time. On the other hand, the refining industry have concerns that this cuts into time<br />
available for the investment needed to upgrade plant and in gaining the necessary<br />
approvals from their companies.<br />
* In relation to timing, the refining industry has also indicated that once new diesel plant<br />
is established to produce 50 ppm sulfur, the old plant will then be converted for 50 ppm<br />
sulfur petrol. Therefore, the Commonwealth’s proposal for the introduction of 50 ppm
sulfur for both petrol and diesel at the same time will be difficult as 6 months will be<br />
required for conversion of plant for 50 ppm petrol after the new diesel plant is<br />
operational.<br />
* The availability of 91 RON and 95 RON fuels at the same time. The FCAI have<br />
expressed concern about the potential for misfuelling of 95 RON vehicles with 91 RON<br />
fuel and resulting maintenance and servicing problems. They want financial incentives to<br />
encourage uptake of 95 RON. The FCAI believe that a competitive disadvantage will<br />
arise for manufacturers of 95 RON vehicles if 91 RON fuel is cheaper because it will<br />
encourage consumers to buy 91 RON vehicles.<br />
* The AIP have requested that a Euro 2 equivalent standard, based on their current<br />
refinery exchange standards, be introduced in 2001 to address petrol substitution issues.<br />
There has also been a general view that operational, as well as environmental, aspects<br />
should be covered by the one instrument. Other stakeholders saw the merit of this view<br />
for 2001.<br />
* The use of pool averaging as compared with flat limits as a way of providing flexibility<br />
for refiners to achieve standards for some parameters, e.g. olefins and aromatics which<br />
affect octane levels.<br />
* Financial incentives to encourage the production of cleaner fuels necessary for the<br />
effective operation of new emissions control technology.<br />
* There has been extensive discussion about the use of additives to enhance octane levels<br />
and their operability and environmental implications. These include MTBE, MMT,<br />
ETBE and biofuels including ethanol.<br />
7. CONCLUSION AND RECOMMENDED OPTION<br />
As demonstrated above, Commonwealth legislation regulating fuel quality standards<br />
would provide the national consistency required to avoid competition problems and trade<br />
barriers that will result from State-specific fuel quality regulations. It is the only option<br />
available that will ensure standards are implemented in time to facilitate the effective and<br />
efficient performance of new emissions control technology necessary to meet tighter<br />
emissions standards implemented through new Australian Design Rules for motor<br />
vehicles. Commonwealth fuel quality legislation capable of mandating fuel specifications<br />
nationally will ensure that fuel of specifications that are essential for the optimal<br />
operation of vehicles will be widely available in Australia.<br />
The Commonwealth Government has clearly stated goals and objectives relating to<br />
improving air quality and reducing toxic and greenhouse emissions from the transport<br />
sector. These goals and objectives will not be met unless cleaner fuels are mandated in<br />
Australia. Commonwealth legislation is the only cost effective option available to ensure<br />
objectives are met in the required timetable.<br />
In implementing fuel standards, the requirements and expectations of the automotive<br />
industry need to be balanced carefully with the production capabilities of the refining<br />
industry and the significant investment that will be required if they are to produce cleaner
fuels. The Commonwealth proposal has been developed in close consultation with both<br />
industries and all stakeholders to ensure the best possible outcome for all Australians and<br />
is recommended as the most viable option for achieving the Government’s objectives.<br />
8. IMPLEMENTATION AND REVIEW<br />
The preferred option, ie the Commonwealth’s proposal for national fuel quality standards,<br />
would be implemented under primary legislation that provides the machinery for<br />
establishing a national fuel quality standards regime. It is proposed that the actual<br />
standards for each of the petrol and diesel parameters would be set in regulations under<br />
the Act. This would provide the necessary flexibility to amend the standards quickly or to<br />
deal with other fuel quality issues as they arise without having to go through the lengthy<br />
process required to amend the legislation.<br />
Under the legislation, statutory independent review will be required two years after the<br />
first set of standards comes into effect, i.e. January 2002, and thereafter every five years.<br />
From January 2002, the Minister will be required to present an annual report to the<br />
Parliament that describes compliance with the legislation, prosecutions made under the<br />
legislation and any other relevant actions, such as whether any regulations were made<br />
under the legislation.<br />
It is not envisaged that compliance will result in paper burden costs in the production and<br />
supply chain as existing record keeping processes, if operated effectively, should be<br />
sufficient. There may only be a requirement that the quality of these processes be<br />
improved to ensure that sufficient records are kept and that they are accurate.<br />
Effectiveness of the Commonwealth’s proposal for national fuel quality standards will be<br />
measured in a number of ways. These include the availability of cleaner fuel to<br />
consumers, measured reductions in emissions compared to business as usual projections,<br />
and the effectiveness of the new advanced emissions control technology.<br />
9. REFERENCES<br />
AATSE (1997) Urban Air Pollution in Australia, Australian Academy of Technological<br />
Sciences and Engineering, Melbourne, October 1997.<br />
ACEA/AAMA/JAMA/EMA (1998) World Wide <strong>Fuel</strong> Charter, European Automobile<br />
Manufacturers’ Association / American Automobile Manufacturers’ Association / Japan<br />
Automobile Manufacturers’ Association / Engine Manufacturers Association, December<br />
1998.<br />
Australian Institute of Petroleum (AIP), 1999a, Statistical Review 1998, Victoria.<br />
Australian Institute of Petroleum (AIP), 1999b, Australian Refinery Product<br />
Characteristics.<br />
ANOP Research Services (1993) Community attitudes to environmental issues, Report<br />
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Auto-Oil Programme (1995) Informal briefing: The Auto-Oil Programme, Brussels, 21<br />
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Ballantyne, V (1995) Particulates and other motor vehicle emissions, Clean Air Society<br />
Seminar: Health Effects of Particulates, Brisbane, 8 December 1995.<br />
BTCE (Bureau of Transport and Communications Economics) (1994) Alternative <strong>Fuel</strong>s<br />
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Information Paper No. 39, AGPS, Canberra, 1994.<br />
______ (1995) Greenhouse Gas Emissions from Australian Transport - Long Term<br />
Projections, Bureau of Transport and Communications Economics Report 88, p.216,<br />
Canberra, March 1995.<br />
California Air Resources Board (1998) Proposed Identification of Diesel Exhaust as a<br />
Toxic Air contaminant, Staff Report, California Air Resources Board, Office of<br />
Environmental Health Assessment, California, June 1998.<br />
______ (1994) Leaflet on the Toxic Air Contaminant Identification Process: Diesel<br />
Exhaust, California Air Resources Board, Sacramento California USA, June 1994.<br />
Carnovale, F., Alviano, P., Carvlaho, C., Deitch, G., Jiang, S., Macaulay, D. & Summers,<br />
M. (1991) Air Emissions Inventory of the Port Phillip Control Region: Planning for the<br />
Future, Environment Protection Authority of Victoria, Melbourne, Victoria.<br />
Clean Air 2000 (1997) Monitor of Public Attitudes in Clean Air 2000 Campaign Report,<br />
Sydney, 1997.<br />
Commission of the European Communities, 1998, Proposal for a Council Directive<br />
relating to limit values for benzene and carbon monoxide in ambient air (1999/c 53/07)<br />
Off. J. Europ. Comm. 24.2.99.<br />
Commonwealth of Australia 1992 <strong>National</strong> Strategy for Ecologically Sustainable<br />
Development, Commonwealth of Australia, AGPS, Canberra.<br />
______ (1996) Sustainable Energy Policy for Australia, Commonwealth of Australia,<br />
Green Paper, Canberra, in AATSE, 1997.<br />
Coffey Partners (1996) Parameter projections for the reviews of ADR 37/01 and ADR<br />
70/00 by ACVEN, report prepared for Department of Transport, Federal Office of Road<br />
Safety, Hawthorn, Victoria.<br />
Coffey Geosciences Pty Ltd, Review of <strong>Fuel</strong> <strong>Quality</strong> Requirements for Australian<br />
Transport, report prepared for Environment Australia, March 2000<br />
Concawe (1995) Motor vehicle emission regulations and fuel specifications in Europe<br />
and the United States, 1995 Update, Concawe, Brussels.<br />
______ (1996) Air quality standard for particulate matter, Concawe Health Management<br />
Group, Brussels.
______ (1997) Motor vehicle emission regulations and fuel specifications in Europe and<br />
the United States, 1997 Update, Concawe, Brussels.<br />
______ (1998) A Study of the Number, size and Mass of Exhaust Particles Emitted from<br />
European Diesel and Gasoline Vehicles under Steady-state and European Driving Cycle<br />
Conditions, Report No 98/51, Brussels, February 1998.<br />
Denison, L., and Chiodo, J. (1996) Respirable Particles in Australia: Current Issues and<br />
Future Directions, paper presented at 13th International Clean Air & Environment<br />
Conference, Adelaide, 1996.<br />
Department of Finance, Handbook of Cost-Benefit Analysis, Australian Government<br />
Publishing Service, 1991.<br />
Department of Industry, Science and Resources (1999) Downstream Petroleum Products<br />
Action Agenda, Commonwealth of Australia.<br />
Department of Transport and Regional Services (1999) Regulatory <strong>Impact</strong> <strong>Statement</strong> -<br />
New Australian Design Rules for Control of Vehicle Emissions.<br />
European Commission (1991) Council Directive 91/542/EEC Amending Directive<br />
88/77/EEC on the approximation of the laws of the Member States relating to the<br />
measures to be taken against the emissions of gaseous pollutants from diesel engines for<br />
use in vehicles, Official Journal of the European Communities, No. L295/1, 25 October<br />
1991.<br />
______ (1996a) Communication from the Commission to the European Parliament and<br />
the Council on a future strategy for the control of atmospheric emissions from road<br />
transport taking into account the results from the Auto/Oil Programme (COM(96) 248<br />
final), 18 June 1997, Brussels<br />
______ (1996b), Proposal for a Directive on the <strong>Quality</strong> of Petrol and Diesel <strong>Fuel</strong>s, in<br />
Europe Energy No 476, 26 September 1996<br />
______ (1997) Resolution on the communication from the Commission to the European<br />
Parliament and the Council on a future strategy for the control of atmospheric emissions<br />
from road transport taking into account the results from the Auto/Oil Programme<br />
(COM(96)0248-C4-0492/96), Official Journal of the European Communities, No<br />
C132/206, 28 April 1997.<br />
Environmental Protection (Diesel and Petrol) <strong>Regulation</strong>s 1999 - (Western Australia)<br />
Environmental Protection Act 1986.<br />
European Parliament, 1997, Report on the proposal for a European Parliament and<br />
Council Directive on the quality of petrol and diesel fuels and amending Council<br />
Directive 93/12/EEC COM(96)0248-C4-0462/96-96/0163(COD).<br />
EPEFE (1995) European Program on Emissions, <strong>Fuel</strong>s and Engine Technologies Report,<br />
ACEA / Europia.
FORS (1997) LPG In-service Vehicle Emissions Study - Supplementary Report No.1 to<br />
Motor Vehicle Pollution In Australia Report, report prepared by the NSW Environment<br />
Protection Authority for the Federal Office of Road Safety and Environment Australia,<br />
May 1997.<br />
Grant, L.D., Graham, J.A., Kotchmar, D.J. & Tilton, B.E. (1993) Health effects of motor<br />
vehicle related criteria air pollutants, International workshop on human health and<br />
environmental effects of motor vehicle fuels and their exhaust emissions, Sydney<br />
Hensley, M (1996) Health and air Research Program - Main Findings in Proceedings of<br />
the Health and Urban Air <strong>Quality</strong> in NSW Conference, NSW Department of Health and<br />
NSW EPA, Sydney, 3-4 June 1996.<br />
James, B. (1994) Perth Photochemical Smog Study: Motor Vehicle Emission Inventory,<br />
WA Department of Transport, Nedlands, WA.<br />
Le Cornu, J and Day, B (1998) LPG is the Best Solution when Optimising Greenhouse,<br />
Clean Air and Buses, Seminar Presentation, Canberra, July 1998.<br />
Manufacturers of Emission Controls Association (1996), Emission Control of Diesel-<br />
<strong>Fuel</strong>led Vehicles, Washington, DC September 1996.<br />
Morgan, G., Corbett, S. and Wlodarczyk, J. (1998) Air Pollution and Hospital<br />
Admissions in Sydney, Australia, 1990 to 1994, Amercian Journal of Public Health,<br />
December 1998, Vol 88. No12.<br />
NEPC (<strong>National</strong> Environment Protection Council), 1998, Ambient Air <strong>Quality</strong> - <strong>National</strong><br />
Environment Protection Measure and Revised <strong>Impact</strong> <strong>Statement</strong> for Ambient Air <strong>Quality</strong>,<br />
26 June 1998, <strong>National</strong> Environment Protection Council Service Corporation.<br />
NRMA: Clean Air 2000 Taskforce (1996a) Monitor of public attitudes: Air quality and<br />
the car 1996, NRMA Ltd, Sydney.<br />
______ (1996b) Shaping Sydney’s Transport: A framework for reform: Discussion paper,<br />
NRMA Ltd, Sydney.<br />
NSW EPA (1994) Who cares about the environment? A benchmark survey of the<br />
environmental knowledge, skills attitudes and behaviour of the people of NSW, NSW<br />
Environment Protection Authority, Sydney.<br />
______ (1996a) Developing a Smog Action Plan for Sydney, the Illawarra and the Lower<br />
Hunter, NSW Government Green Paper, Chatswood, NSW.<br />
______ (1996b) Developing an Air <strong>Quality</strong> Management Plan for Sydney, the Illawarra<br />
and the Lower Hunter, Chatswood, NSW.<br />
______ (1996c) Metropolitan Air <strong>Quality</strong> Study: Outcomes and Implications for<br />
Managing Air <strong>Quality</strong>, NSW.
______ (1998) Action for the Air: the NSW Government’s 25 Year Air <strong>Quality</strong><br />
Management Plan, February 1998.<br />
______ (1999) Preliminary Economic Analysis of Adopting New Vehicle Emission<br />
<strong>Standards</strong>, Economics and Environmental Reporting Branch, NSW EPA, April 1999.<br />
Prime Minister (1997), The Hon John Howard MP, <strong>Statement</strong> Safeguarding the Future"<br />
Australia’s Response to Climate Change, 20 November 1997<br />
Prime Minister, May 1999, The Hon John Howard MP, Letter to Senator Meg Lees,<br />
Changes to the Goods and Services Tax (GST) including Measures for a Better<br />
Environment, Costing of Commonwealth and States Measures, 31 May 1999.<br />
Pope, C et al (1995) Am J Respir Crit Care Med 151 669-674.<br />
QDOE (1998) Draft Strategy for Managing Air <strong>Quality</strong> in South-East Queensland,<br />
Queensland Department of the Environment, February 1998.<br />
Reid, A (1997) Air Pollution, Do We Have a Problem ?, paper presented to seminar Air<br />
Pollution and Health - the Facts, Canberra, 10 November 1997.<br />
Roads and Traffic Authority - RTA (1994) Submission to the NSW Parliamentary Select<br />
Committee Upon Vehicle Emissions, RTA, Sydney.<br />
Sivak, A. (1993) Characterisation and health effects of gasoline and exhaust emissions,<br />
International workshop on human health and environmental effects of motor vehicle fuels<br />
and their exhaust emissions, Sydney 6-10/4/92, International Programme on Chemical<br />
Safety, Department of Health, Housing, Local Government and Community Services, and<br />
the Clean Air Society of Australia and New Zealand, pp 101-173.<br />
SoE (1996) Australia: State of the Environment 1996, Independent Report by the State of<br />
the Environment Advisory Council to the Commonwealth Minister for the Environment,<br />
CSIRO Publishing, Collingwood, Victoria.<br />
<strong>Standards</strong> Australia, 1990, Australian Standard for Petrol (gasoline) for motor vehicles,<br />
AS 1876-1990, <strong>Standards</strong> Australia, North Sydney, NSW.<br />
<strong>Standards</strong> Australia, 1998, Australian Standard for Automotive Diesel <strong>Fuel</strong>, AS 3570 -<br />
1998, <strong>Standards</strong> Australia, North Sydney, NSW.<br />
US EPA (1996) Air <strong>Quality</strong> Criteria for Particulate Matter:v1, environmental Criteria<br />
and Assessment, Research Triangle Park, North Carolina.<br />
Victorian Environment Protection Authority - Vic EPA(1993) Annual Report 1992-3, Vic<br />
EPA, Melbourne.<br />
______ (1994) Victorian Transport Externalities Study: Volume 4, Vic EPA, Melbourne.<br />
______ (1995) Victorian State of the Environment Report, Vic EPA, Melbourne.
______ (1999) Air Emissions Inventory - Port Phillip Region.<br />
______ (2000) Draft Air <strong>Quality</strong> Improvement Plan, Port Phillip Region, Victorian<br />
Environment Protection Authority, Melbourne.<br />
WA DEP (1996) The Perth Haze Study 1994-96 - Summary and Major Findings,<br />
Department of Environmental Protection, Perth, November 1996
APPENDIX 1<br />
Table A3.1 Australian diesel - product characteristics summary - 1998<br />
<strong>Fuel</strong> parameter<br />
Sample size<br />
(n)<br />
Standard<br />
deviation<br />
Mini<br />
mum<br />
Maxi<br />
mum<br />
Avera<br />
ge<br />
Ash, mass % 49 0.001 0.000 0.010 0.001<br />
CFPP, deg C: Summer 37 2.174 -7 2 -1<br />
CFPP, deg C: Winter 53 0.643 -5 -2 -4<br />
Cetane Index 2031 3.287 43.0 64.0 51.4<br />
Cloud Pt, deg C: Summer 756 3.021 -18 14 4.7<br />
Cloud Pt, deg C: Winter 510 2.673 -6 14 1<br />
Copper strip, 3h @ 150C 1238 1a 2a 1a<br />
Density, @ 15C, kg/L 2036 0.0087 0.8122 0.8731 0.8462<br />
Distillation:<br />
50% recov’d, deg C 1447 5.813 233.1 300.0 277.7<br />
90% recov’d, deg C 2036 8.194 257.0 379.7 334.4<br />
95% recov’d, deg C 1324 7.728 318.5 384.2 352.8<br />
Flash Pt, PM, deg C 2032 6.845 59.0 105.0 79.7<br />
Oxidation Stab., 4/48h, mg/L 48 4.782 0.0 18.0 3.4<br />
10% Distillation residue, % mass 56 0.0215 0.0000 0.1400 0.0437<br />
Water & sediment, % mass 769 0.0096 0.0000 0.0500 0.0092<br />
Sulfur, % mass 2035 0.081 0.01 0.55 0.13<br />
Viscosity @ 40C, cSt 54 0.283 2.18 4.00 3.24<br />
Source: Australian Institute of Petroleum, 1999
Table A3.2 Regular unleaded petrol (ULP) - product characteristics summary -<br />
1998<br />
<strong>Fuel</strong> parameter<br />
Sample<br />
size (n)<br />
Standard<br />
deviation<br />
Mini Maxi Aver<br />
mum mum age<br />
Benzene, %volume 1252 0.717 0.30 5.00 2.58<br />
Colour 1197<br />
Copper strip 3H @ 50°C 944 1A 1B 1A<br />
Density @15°C kg/L 1633 0.007<br />
Distillation<br />
0.701<br />
1<br />
0.761<br />
4<br />
Purpl<br />
e<br />
0.735<br />
0<br />
10% evap, deg C 1668 3.163 29.1 56.5 46.0<br />
50% evap, deg C 1668 5.135 63.9 110.0 86.3<br />
90% evap, deg C 1668 7.496 129.0 185.0 155.1<br />
FBP, deg C 1690 10.945 152.3 232.8 197.0<br />
Evap @ 70°C, vol % 1522 3.913 18.3 47.0 34.3<br />
Existent gum, mg/L 63 3.631 0.0 34.0 3.9<br />
Induction period, min 51 202.083 240 1440 >400<br />
Lead, mg/L 1577 0.473 0.00 6.00 1.40<br />
Motor octane number 1314 0.431 81.6 86.8 82.5<br />
Research octane number 1666 0.592 90.3 95.0 91.6<br />
Phosphorus, mg/L 53 0.112 0.00 0.70 0.38<br />
Sulfur, % mass 1106 0.10 0.000 0.200 0.015<br />
Volatility<br />
RVP, kPa, January 122 2.868 61.0 81.0 71.9
RVP, kPa, February 115 4.309 49.5 93.0 72.7<br />
RVP, kPa, March 141 3.079 64.5 86.3 76.0<br />
RVP, kPa, April 138 3.562 68.2 87.7 78.8<br />
RVP, kPa, May 107 8.762 69.4 94.0 84.1<br />
RVP, kPa, June 134 5.087 70.4 96.8 86.1<br />
RVP, kPa, July 130 5.222 66.2 98.0 85.6<br />
RVP, kPa, August 127 5.333 62.0 95.0 84.9<br />
RVP, kPa, September 129 5.007 64.0 90.7 80.8<br />
RVP, kPa, October 136 4.527 61.4 89.2 77.0<br />
RVP, kPa, November 136 4.398 55.0 88.7 73.1<br />
RVP, kPa, December 144 3.126 59.0 84.0 70.9<br />
Aromatics, % volume 212 5.240 10.2 45.0 27.3<br />
Olefins, % volume 32 7.706 0.0 37.8 17.1<br />
Total number of batches: 1690. Total refinery<br />
throughput: 12218 ML<br />
Source: Australian Institute of Petroleum
Table A3.3: Premium unleaded petrol (PULP) - product characteristics<br />
summary - 1998<br />
<strong>Fuel</strong> parameter<br />
Sample<br />
size (n)<br />
Standard<br />
deviation<br />
Mini Maxi Aver<br />
mum mum age<br />
Benzene, %volume 152 0.637 1.30 5.00 3.29<br />
Colour 149<br />
Copper strip 3H @ 50°C 131 1A 1B 1A<br />
Density @15°C kg/L 211 0.0072<br />
Distillation<br />
0.722<br />
5<br />
0.771<br />
8<br />
Yello<br />
w<br />
0.747<br />
5<br />
10% evap, deg C 203 3.951 37.0 62.6 47.9<br />
50% evap, deg C 203 4.789 89.0 147.9 102.5<br />
90% evap, deg C 203 5.570 131.5 181.0 155.9<br />
FBP, deg C 214 8.480 163.0 232.5 198.3<br />
Evap @ 70°C, vol % 211 3.411 11.5 35.5 25.4<br />
Existent gum, mg/L 49 3.659 0.0 38.0 7.9<br />
Induction period, min 36 63 600.0 1100.<br />
0<br />
Lead, mg/L 214 0.523 0.00 3.00 1.12<br />
Motor octane number 197 0.668 82.9 88.4 85.5<br />
Research octane number 211 0.580 95.0 98.4 96.1<br />
Phosphorus, mg/L 32 0.173 0.00 0.70 0.08<br />
Sulfur, % mass 193 0.010 0.000 0.100 0.012<br />
Volatility<br />
RVP, kPa, January 21 5.080 64.0 95.8 76.1<br />
480
RVP, kPa, February 14 3.100 51.0 96.1 77.3<br />
RVP, kPa, March 13 2.684 72.0 85.5 80.2<br />
RVP, kPa, April 19 2.868 66.0 89.3 83.3<br />
RVP, kPa, May 18 3.278 70.0 96.0 84.7<br />
RVP, kPa, June 21 3.758 9.3 100.0 87.9<br />
RVP, kPa, July 17 6.914 72.0 98.0 85.1<br />
RVP, kPa, August 12 8.940 61.3 98.0 79.8<br />
RVP, kPa, September 18 7.214 58.5 92.3 78.1<br />
RVP, kPa, October 19 2.634 50.5 92.0 77.0<br />
RVP, kPa, November 19 7.060 66.0 88.0 78.2<br />
RVP, kPa, December 23 3.752 60.0 81.0 71.3<br />
Aromatics, % volume 32 5.494 22.9 50.0 35.7<br />
Olefins, % volume 9 6.916 7.8 28.9 17.0<br />
Total number of batches: 214. Total refinery<br />
throughput: 640 ML<br />
Source: Australian Institute of Petroleum
APPENDIX 2: Summary of Assessment of Regulatory Options<br />
Assessment<br />
criteria<br />
1. Provides a<br />
nationally<br />
consistent<br />
approach to<br />
fuel quality<br />
standards.<br />
2. Is consistent<br />
with<br />
preceding<br />
Government<br />
policy<br />
decisions on<br />
this matter<br />
3. Ensures<br />
that<br />
appropriate<br />
fuel is<br />
available in<br />
line with the<br />
timetable for<br />
the<br />
implementatio<br />
n of new<br />
ADRs.<br />
5. Does not<br />
restrict<br />
competition<br />
and trade.<br />
Option 1.<br />
Business as<br />
Usual<br />
State specific<br />
legislation<br />
creating<br />
competition<br />
problems and<br />
trade barriers.<br />
Some States or<br />
Territories<br />
without any<br />
standards.<br />
Inconsistent with<br />
preceding<br />
Government<br />
policy decisions.<br />
Would not meet<br />
timetable under<br />
BAU. Not all<br />
States would<br />
regulate.<br />
Appropriate fuel<br />
not produced by<br />
all refineries.<br />
Option 2:<br />
Industry<br />
agreements<br />
Tend to favour<br />
refinery<br />
capabilities<br />
within a<br />
jurisdiction. Not<br />
enforceable.<br />
Would not meet<br />
objective in a<br />
consistent way.<br />
Inconsistent<br />
with preceding<br />
Government<br />
policy decisions.<br />
Favours<br />
refinery<br />
capabilities<br />
within a<br />
jurisdiction.<br />
Investment<br />
necessary would<br />
not occur in<br />
time.<br />
State specific<br />
Industry<br />
legislation<br />
agreements with<br />
currently being<br />
specific states<br />
implemented will<br />
could cause<br />
restrict<br />
competition<br />
competition and<br />
problems.<br />
trade.<br />
Option 3: State<br />
<strong>Regulation</strong><br />
<strong>Regulation</strong>s differ in<br />
each State creating<br />
competition<br />
problems and trade<br />
barriers. Some states<br />
will not regulate.<br />
Inconsistent with<br />
preceding<br />
Government policy<br />
decisions.<br />
Not all jurisdictions<br />
would introduce<br />
regulations in time.<br />
State specific<br />
legislation favours<br />
local refining<br />
industry capabilities.<br />
Timeframe would<br />
not be met.<br />
State specific<br />
legislation will<br />
restrict competition<br />
and create trade<br />
barriers.<br />
Option 4: NEPM<br />
Implementation<br />
through State<br />
legislation.<br />
Possible for State<br />
specific factors to<br />
be incorporated.<br />
States can pull<br />
out of process.<br />
Would not<br />
achieve<br />
consistency with<br />
preceding<br />
Government<br />
policy decision<br />
on the fuel<br />
quality,<br />
NEPM<br />
development<br />
process too slow.<br />
Timetable would<br />
not be met.<br />
May assist in<br />
achieving a<br />
national<br />
approach,<br />
however,<br />
conditions<br />
relating to state<br />
legislation could<br />
create barriers.<br />
Option 7:<br />
Commonwealth<br />
legislation<br />
Would apply<br />
uniformly across<br />
the jurisdictions<br />
and provide<br />
national<br />
consistency.<br />
Commonwealth<br />
proposal is<br />
consistent (and<br />
driven) by<br />
preceding<br />
Government<br />
policy decisions.<br />
Proposed<br />
timetable for<br />
introduction of<br />
standards will<br />
ensure<br />
appropriate fuel<br />
is available for<br />
new ADRs -<br />
incorporated in<br />
objectives.<br />
Will ensure<br />
uniform national<br />
standards and<br />
avoid competition<br />
problems -<br />
overrides state<br />
regulations.
Appendix 3: Summary of Costs and Benefits<br />
COSTS<br />
Compliance<br />
Socioeconomic<br />
Environmental<br />
BENEFITS<br />
Compliance<br />
Socioeconomic<br />
Environmental<br />
States and<br />
Territories<br />
Commonwealth<br />
legislation will<br />
override<br />
inconsistent<br />
standards in the<br />
jurisdictions.<br />
Potential closure<br />
of local refineries<br />
- implications for<br />
dependent<br />
industries eg<br />
petrochemicals.<br />
Concern about<br />
worse<br />
environmental<br />
outcome from less<br />
stringent standards<br />
States and<br />
Territories<br />
Reduced<br />
monitoring and<br />
enforcement for<br />
State agencies.<br />
Improved health<br />
and reduced<br />
associated costs.<br />
Level playing<br />
field for industry.<br />
Decrease in<br />
emissions from<br />
road transport.<br />
Refining Industry<br />
Average capital<br />
investment per refinery<br />
of $185M. An increase<br />
in operating<br />
expenditure of $17M<br />
per refinery.<br />
Possible closure of<br />
refineries and related<br />
industries - potential<br />
job losses. Note that job<br />
loses may occur<br />
through restructuring,<br />
separate from the fuel<br />
quality standards<br />
process. Timing issue<br />
for investment<br />
approvals etc.<br />
Potential for increased<br />
greenhouse gas<br />
emissions at refineries.<br />
Refining Industry<br />
Consistent approach to<br />
fuel standards<br />
nationally Reduced<br />
compliance costs in the<br />
long-term. Certainty for<br />
future investment<br />
Avoided competition<br />
problems and trade<br />
barriers - level playing<br />
field. More viable<br />
industry.<br />
Cleaner fuels -<br />
improved public<br />
profile.<br />
<strong>Fuel</strong> importers &<br />
distributors<br />
Comprehensive and<br />
accurate record<br />
keeping procedures.<br />
Potential for<br />
increased storage<br />
costs for<br />
distributors.<br />
Small increase in<br />
the price of fuel<br />
distributors<br />
purchase from<br />
major refiners.<br />
<strong>Fuel</strong> importers &<br />
distributors<br />
Reduced<br />
compliance costs<br />
due to national<br />
uniform standards.<br />
Certainty of future<br />
requirements.<br />
Protection from<br />
unscrupulous<br />
operators that<br />
adulterate fuel -<br />
damaging business<br />
and reputations.<br />
Reduced<br />
adulteration of fuel<br />
causing harmful<br />
toxic effects.<br />
<strong>Fuel</strong><br />
retailers<br />
Comprehensi<br />
ve and<br />
accurate<br />
record<br />
keeping<br />
procedures.<br />
Small<br />
increase in<br />
the price of<br />
fuel<br />
purchased<br />
from<br />
distributors.<br />
<strong>Fuel</strong><br />
retailers<br />
Consistent<br />
approach.<br />
Reduced<br />
compliance<br />
costs.<br />
Reduced<br />
evaporative<br />
emissions at<br />
the pump and<br />
less<br />
adulteration<br />
of fuel.<br />
Automotive<br />
Industry Consumers<br />
Misfuelling<br />
issue if 91 &<br />
95 RON fuel<br />
is available<br />
at the same<br />
time.<br />
Potential<br />
competitive<br />
disadvantage<br />
Increased<br />
fuel prices at<br />
the pump -<br />
diesel - 1.5c<br />
per litre<br />
petrol - 1.1c<br />
per litre<br />
Potential for<br />
increased<br />
refinery<br />
emissions.<br />
Automotive<br />
Industry Consumers<br />
More<br />
efficient<br />
operation of<br />
vehicle<br />
technology -<br />
reduced<br />
emissions.<br />
Appropriate<br />
fuel available<br />
for new<br />
ADRs<br />
Effective<br />
emissions<br />
control<br />
technology -<br />
reduced<br />
emissions.<br />
More<br />
efficient<br />
operation of<br />
vehicles -<br />
improved<br />
fuel<br />
economy.<br />
Avoided<br />
health costs.<br />
Net health &<br />
environment<br />
al benefits<br />
between<br />
$1577M &<br />
$2180M.<br />
Improved air<br />
quality -<br />
substantial<br />
reductions in<br />
emissions.<br />
Improved<br />
health.
APPENDIX 4<br />
LIST OF STAKEHOLDERS<br />
* ACT Department of Urban Services<br />
* AGL<br />
* AIR<br />
* Australian Automobile Association<br />
* Australian Competition & Consumer Commission<br />
* Australian Institute of Petroleum<br />
* Australian LPG Association<br />
* Australian Natural Gas Vehicles Council<br />
* Australian Petroleum Agents & Distributors Assoc.<br />
* Australian Service Station Association<br />
* BP Australia<br />
* Burmah <strong>Fuel</strong>s<br />
* Burn Bank Consulting<br />
* Caltex Australia<br />
* Commercial Vehicle Industry Association<br />
* Commonwealth Department of Industry Science & Resources, Petroleum Division<br />
* Commonwealth Department of Industry, Science and Resources, Automotive Industry<br />
Section<br />
* Commonwealth Department of Transport and Regional Servicese<br />
* Australian Greenhouse Office<br />
* Conservation Council of WA<br />
* CSIRO<br />
* Department of Environment & Heritage, Qld<br />
* Department of Environment & Land Management, TAS
* Department of Environmental Protection, WA<br />
* Department of Infrastructure, Energy and Resources, Tasmania<br />
* Department of Lands, Planning & Environment, NT<br />
* Department of Natural Resources, Victoria<br />
* Department of Transport, Queensland<br />
* Dept. of Transport, Tasmania<br />
* Department of Transport, WA<br />
* Department of Transport & Works, NT<br />
* Department of Transport, the Arts & Urban Planning, SA<br />
* Environment Protection Authority, NSW<br />
* Environment Protection, Dept of Urban Services, ACT<br />
* Environment Protection Authority, Victoria<br />
* Federal Chamber of Automotive Industries<br />
* Federal Office of Road Safety<br />
* Federation of Automotive Products Manufacturers<br />
* Gull Petroleum WA<br />
* Iain Cameron Consultancy<br />
* Liberty Oil Pty Ltd<br />
* Minerals & Petroleum Dept of Natural Resources & Environment, Victoria<br />
* Minerals Council of Australia<br />
* Mobil Oil Australia<br />
* Motor Traders Association of Australia<br />
* <strong>National</strong> Environmental Consultative Forum<br />
(C/- Tasmanian Conservation Trust, Inc)<br />
* <strong>National</strong> Farmers Federation<br />
* <strong>National</strong> Road Transport Commission
* NRMA<br />
* NSW Cabinet Office<br />
* Premiers Departments<br />
* Road Transport Forum<br />
* Roads & Traffic Authority - NSW<br />
* Shell Australia<br />
* Society of Automotive Engineers<br />
* Sustainable Energy Group<br />
* The Treasury<br />
* Victorian Farmers Federation<br />
* VicRoads