Australian Automobile Association
Submission to
Environment Australia
Fuel Quality Review Proposed Standards for Fuel Parameters
(Petrol and Diesel)
Revised Commonwealth Position
October 2000
01/11/00
1.
INTRODUCTION
The Australian Automobile Association (AAA) welcomes the opportunity to make a
supplementary submission to the Department of the Environment and Heritage,
Environment Australia Fuel Quality Review on National Fuel Quality Standards,
revised Commonwealth position.
The AAA is the Federal representative of the State and Territory motoring clubs, its
members being the ;
•
•
•
•
•
•
•
•
NRMA Limited
Royal Automobile Club of Victoria (RACV) Ltd
The Royal Automobile Club of Queensland Limited.
The Royal Automobile Association of South Australia, Inc
The Royal Automobile Club of Western Australia, (Incorporated)
The Royal Automobile Club of Tasmania
Automobile Association of Northern Territory Inc. and
Royal Automobile Club of Australia.
The AAA represents over 6 million motorists, being the total membership of these
clubs and associations.
This supplementary submission in response to the revised Commonwealth Revised
Position is in addition to the initial consultation and AAA response in June 2000.
2.
GENERAL PRINCIPLES
The AAA concurs with the principle that fuel standards should be used to manage
those fuel qualities/parameters that are known to have the potential to impact
adversely on the environment. Other fuel parameters which influence the operability
of vehicles are also important to ensure consumer satisfaction and AAA welcomes
accommodation of these in the National Fuel Quality Standards Bill 2000.
AAA also welcomes the inclusion of LPG into early discussions on other fuel
standards, as requested in the original AAA submission, June 2000.
Fuel standards that address environmental and/or health issues should align with UN
ECE specifications but may vary, if necessary, in order to achieve the appropriate
Australian outcome.
Timing of fuel standards must take into account best available technology already
available to other markets, particularly Europe, to enable early introduction of those
technologies into the Australian market.
_____________________________________________________________________________
Australian Automobile Association
National Fuel Quality Standards – Revised Commonwealth Position
Page 2 of 5
01/11/00
3.
COMMENTS ON REVISED PROPOSAL
3.1 SULPHUR STANDARDS
3.1.1 Diesel – AAA supports the original EA proposal of 500ppm at 1st January 2002
in line with the emissions ADR for new diesel vehicles. This will also enable the
introduction of more advanced diesel emission technologies.
3.1.2 ULP and PULP – The EA revised position of harmonisation with Euro 2 in
2002 (500ppm ULP, 150ppm PULP) is supported. However, some mechanism or
wording should be included to enable the earlier introduction of 150ppm ULP on a
best endeavours basis for those companies able to achieve it.
3.1.3 LRP – the desirability of reducing sulphur to 150ppm appears sensible in the
short term, particularly as some of the fuel suppliers are using PULP with an additive.
However, the longer term continuation of the LRP is likely to be based on a separate
product and its economic viability may be dependent on ability to use a higher
sulphur base (500ppm). Therefore, given the potentially low future volumes of LRP
we see no justification for forcing sulphur lower than 500ppm.
3.1.4 Further sulphur reductions – AAA believes that the desirability of moving to
even lower sulfur levels depends on the environmental benefits from this further
reduction. The level and timing of further sulfur reductions must, however, enable
vehicle technology, available in volume in other markets, to transfer to the Australian
market at the earliest opportunity. Specific sulphur levels should be cognicent of
European levels when those levels are finally decided.
3.2 BENZENE
AAA supports the original EA proposal for Benzene levels to be capped at 3%
maximum from 1st Jan 2002. Where State or Territory legislation requires a lower
Benzene level, then those lower limits must be applied. The Euro 3 limit of 1%
should apply from 1 st Jan 2005.
3.3 AROMATICS
The revised EA position of 45% pool average and 48% capped for 1st Jan 2002
appears high, given that the original position was 45% max by volume. Western
Australian standards require 42% and it is reported that the fuel companies had little
problem achieving this requirement (albeit recognising the local refinery capability
and cross purchasing of fuel between companies). In addition, MTBE was not used
to achieve this level, which itself follows the World trend to remove MTBE as an
octane enhancer.
3.4 CLEANERBURN
AAA believes that the use of an alternative to meeting the lower sulphur level
(500ppm) must only be considered as a second option if the fuel companies can
demonstrate that their ability to achieve the lower sulphur level by the proposed date
is impossible. If Cleanerburn has to be used then it must be clearly demonstrated
from testing to have no detrimental effect on the environment over and above the
proposed fuel with 500ppm sulphur. It should be noted that some concerns were
raised in Europe by the fuel companies themselves over the environmental benefits
and use of this additised fuel so why it is therefore satisfactory for Australia must be
questioned and justified.
_____________________________________________________________________________
Australian Automobile Association
National Fuel Quality Standards – Revised Commonwealth Position
Page 3 of 5
01/11/00
3.5 ADDITIVES
We would like to express our concern over the change in approach by the Federal
Government to the treatment of fuel additives. The revise approach identifies that any
additives will be allowed unless they are specifically prohibited by the Minister.
This change from the previous approach where the approval of the Minister was
required could enable an additive to be used which does not necessarily have a
quantifiable environmental benefit..
There are many additives available for which claims are made but it cannot be
demonstrated in a rigorous manner that their claims are valid. The change in
approach will allow these additives to continue to be sold and possibly even claim
government approval.
AAA therefore recommends that that any additives must be shown to have a
demonstrated benefit. This benefit needs to be proved through validation under a
recognised testing procedure.
The onus of proof should remain with the company that wishes to use the additive.
This will not be a problem for any of the reputable additives used by the major oil
companies or their suppliers as many of these additives are used abroad and will
have tests results available. A desktop verification by the Agency could then suffice.
Existing additives could be given an amnesty period of 12 months to enable the
Agency time to verify existing additives in the market.
4.
ADDITIONAL COMMENTS
4.1 OPERABILITY STANDARDS
AAA retains the belief that, over and above the need for Environmental fuel qualities,
there remains the need for Operability Standards to ensure correct driveability of
vehicles. Operating parameters should therefore be included with environmental
parameters in the overall fuel specification as one instrument and defined under the
arbitration of the Fuel Standards Consultative Committee, which has yet to be
formed.
In advance of this, AAA is working with Australian Institute of Petroleum (AIP) and
Federal Chamber of Automotive Industries (FCAI) to enable the early introduction of
Operability Standards on a voluntary basis by 1st Jan 2001. It is recommended that
these standards form the basis of any further legislated requirements in due course.
4.2 TEST METHODS
The Commonwealth position makes no reference to specific test methods which
should be used to quantify each of the parameters proposed. AAA believes that it is
important to clearly qualify those test methods to be used in line with those specified
for the Euro standards.
The specific test methods will be identified within the draft Operability Standards.
4.3 AFTERMARKET ADDITIVES AND DEVICES
Whilst recognising that the National Standards apply to the specification of sold fuel,
they do not apply to any post-sale additives or devices which may claim to offer fuel
economy savings, valve seat protection for leaded engines to run on unleaded, lower
emissions etc.
_____________________________________________________________________________
Australian Automobile Association
National Fuel Quality Standards – Revised Commonwealth Position
Page 4 of 5
01/11/00
This is an area of great concern for the motoring clubs as many products continue to
be sold, often at a high price, which are of little real value. In some cases the
additives may have a negative environmental effect on the vehicles emissions, thus
negating any benefits from using an improved fuel (e.g. using a Euro 3 level
unleaded fuel in an engine requiring leaded
The AAA would welcome comment from Environment Australia on any mechanism
which can be put in place, such as an additives/devices register, which only
references or allows use of such product if their claims have been substantiated. We
recognise that this also falls under the area of Consumer Affairs or Trading Practices,
however they have been unable to achieve any real success against sellers of such
products as it is a long winded process to get evidence of product benefits and effect.
Nipping these products in the bud, by putting the onus on the supplier to prove the
benefit before gaining Government endorsement, would allow better control over
spurious claims and sales.
_____________________________________________________________________________
Australian Automobile Association
National Fuel Quality Standards – Revised Commonwealth Position
Page 5 of 5