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| Biodiesel Blending Submission |
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The DEH are currently seeking submissions from interested parties on whether there should be a new biodiesel blend standard introduced in Australia. Australian Biofuel Users have added their support to a group submission of over 20 other interested parties under the banner of the Biodisel Association of Australia and Renewable Fuels Australia (soon to merge into "Biofuels Association of Australia).
The submission follows.
DEPARTMENT OF ENVIRONMENT AND HERITAGE DISCUSSION PAPER, “STANDARDISING DIESEL/BIODIESEL BLENDSNovember, 2006.
Executive Summary
These comments are made on behalf of the Biodiesel Association of Australia (BAA) and Renewable Fuels Australia (RFA) and have been distilled from written and oral comments received from the organisations listed in Attachment ‘A’ to this submission. BAA and RFA are currently negotiating the formation of a single biofuels industry association to be known as the Biofuels Association of Australia.
In his forward to the discussion paper, Minister Ian Campbell states that the paper represents an assessment of diesel/biodiesel blends as part of a package of measures to help address market barriers and restore consumer confidence in the Biofuels industry.
The Minister further states that “Wide ranging stakeholder input will help achieve fuel quality standards for diesel/biodiesel blends that meet the needs of Australian motorists and allows for optimum vehicle and environmental performance.
The report in its “Background” section states that the objectives of the act are to:
(a) regulate the quality of fuel supplied in Australia in order to: (i) reduce the level of pollutants and emissions arising from the use of fuel that may cause environmental and health problems; (ii) facilitate the adoption of better engine technology and emission control technology; (iii) allow the more effective operation of engines and
(b) ensure that, where appropriate, information about fuel is provided when the fuel is supplied
BAA and RFA contend that rather than achieve these objectives, the introduction of diesel/biodiesel blend standards, as proposed in the discussion paper, will have a negative effect on the development of the Australian biodiesel industry, and inhibit the industry’s innovative potential to increase the environmental performance of blended fuels.
The environmental benefits of biodiesel and biodiesel/automotive diesel blends have been well documented. To confirm much of the overseas data Natural Fuels Australia Limited NFAL commissioned the Charles Darwin University to conduct an independent Demonstration Program of biodiesel over a six-month period in 2005/06, using B100 made from 90% palm oil and 10% soy oil meeting the European Standard for Biodiesel EN 14214. A summary of the results is included in Attachment B.
Further, BAA and RFA contend that the comments and alternative solutions proposed by the industry, in response to the DEH discussion paper, will accelerate, rather than impede, the achievement of the Minister’s stated objectives.
Fuel StandardsThere is an Australian Quality Standard for automotive diesel fuel and also for neat fatty acid methyl esters (Biodiesel - B100).
Fuel that meets the Fuel Standard (Automotive Diesel) Determination 2001- as amended is considered suitable for use in diesel engines available in the Australian market.
Fuel that meets this automotive diesel standard is considered appropriate for use by:
a) Department of the Environment and Heritage b) Australian and international diesel engine manufacturers and distributors c) Fuel Producers/Distributors d) End Users
Fuel that meets this automotive diesel standard also qualifies for fuel tax credits under the Fuel Tax Act 2006, and should continue to do so.
The Biodiesel Industry has concerns that creating a blend standard will create market confusion for consumers, depict the recently adopted Fuel Tax amendment as flawed, and thereby destabilize the alternative fuel industry by reducing market competitiveness and closing markets.
This situation is made worse by the phasing out of EGCS and the additional administration the EGCS entails – industry experience suggests that few if any customers have shown any interest in using the scheme.
Several Australian biodiesel producers have successfully demonstrated their ability to produce automotive diesel/biodiesel blends, at and above 20% biodiesel, that verifiably meet the automotive diesel standard. Producers also advise that they do not discount the future potential of higher blends being developed that meet the automotive diesel standard, provide the required fuel quality for motorists, and simultaneously achieve markedly higher reductions of GHG emissions.
The automotive diesel standard is a performance standard which, when met, deems a fuel fit for use in diesel engines. It allows for differences in the nature of crude oils used by refineries to produce automotive diesel, and most hydrocarbon diesel producers regularly seek density waivers for their products.
The industry contends that biodiesel should be considered no different from any other feedstock used in the manufacture of a fuel that meets all the requirements of the automotive diesel standard. It is however imperative that the biodiesel used in any blend comply with the Australian biodiesel standard for B100 - Fuel Standard (Biodiesel) Determination 2003.
This should be guaranteed as Australian biodiesel producers do not qualify for the producer grant of 38.143 cents per litre unless the fuel they manufacture complies with the B100 standard. In addition, an excise manufacturer’s licence must be held to produce biodiesel or biodiesel blends
DEH has been concerned with enforceability of the quality of biodiesel blends, and in particular those blends offered for retail sale.
The industry offers to DEH the proposal of an industry managed Quality Management System to facilitate the traceability of fuel from refinery to retail outlets and to ensure on going quality. In particular, it would ensure that only fuel complying with the B100 Australian Standard be used in blended fuels. Biodiesel industry members acknowledge quality management as one of the most important issues, and the majority agree that an industry managed scheme must be enacted as soon as possible. It is further suggested that a joint government/industry working group should be established to review the operation of the programme. However, an industry in decline cannot format effective policy, adhering to the existing diesel Standard and tax regime will create a stable foundation upon which to build an industry capable of achieve the goals of the industry and Government.
In addition, the industry considers that there are certain parameters and test methods for B100 quality standard that could be strengthened and more appropriate test methods of evaluating the resulting blend. .
B100 tests: - Oxidation Stability – increase to 8 hours - Filterability – add - Acid Number – reduce to 0.5
Blend tests: - Oxidative Stability – change to Rancimat method as per B100 - Filterability – make consistent (Stuart to check) - SimDist via GC to show up contamination
In the resulting blend, 3 characteristics for diesel are less relevant. The Industry would like a waiver on these parameters;
- Colour – allow greater range due to variation in feedstock colouring, perhaps consider substituting clarity - Density – allow up to the density of Biodiesel B100 - Viscosity – allow up to the density of Biodiesel B100
Variations to Test Methods
Polyaromatic Hydrocarbons (PAHs) – Biodiesel interferes with this method and provides an erroneous result. We request that this parameter be reported as a calculated result derived from the PAH value of the diesel component. As there are no PAHs present in biodiesel, the result can be determined as a linear calculation.
Distillation T95 – It is our opinion that the test method for this parameter, ASTM D86, can provide erroneous results for blends in excess of 10% biodiesel. As a consequence we request that method ASTM D1160, Distillation at Reduced Pressure, be employed to evaluate this property.
Cetane Index – This test method does not provide valid results for blends of diesel and biodiesel. There are two approaches that can be taken to overcome this.
· Should the results of the components both be greater than the requirement of 46 then the result can be reported as >46. · Alternatively, the cetane number can be measured physically via any of the methods currently set down in the biodiesel standard.
In relation to the specific options raised in the discussion paper:
(1) We maintain there is no need for mandatory labelling of any biodiesel – hydrocarbon diesel blend containing up to 5% biodiesel; it should be considered as an additive.
(2) For blends containing in excess of 5% biodiesel, that conform to the automotive diesel standard, the following labelling should be MANDATORY.
THIS FUEL CONTAINS A BLEND OF AUTOMOTIVE DIESEL AND BIODIESEL AND COMPLIES WITH THE AUSTRALIAN DIESEL FUEL STANDARD - Fuel Quality Standards Act 2000 (as amended).
This labelling should be prominently displayed at the point of sale.
(3) The industry can see no logical reason for the introduction of B5, B20 or any other blend standard when: a. the sole concern of the motorist is that the fuel product they buy is suitable for use (fit for purpose) in their diesel engine, and this is assured by the diesel standard, and b. their engine manufacturer supports the use of the fuel, and OEMs have already accepted diesel fuel that complies with the Australian automotive diesel standard.
Logically it follows that there is no need for development of test methods for B5 or B20 blends.
(4) There may be incidences where, for various safety or environmental reasons, users may wish to use higher blends which do not meet the automotive diesel standard. Blends that do not meet the diesel standard cannot be marketed as Diesel and if retailed, signboards, pumps and price boards must clearly indicate that it is a Diesel/Biodiesel Blend or B100. The label suggested in (2) above cannot be applied to fuels in this category.
This submission is made on behalf of the Biodiesel Association of Australia and Renewable Fuels Australia and is supported by the follow members of the Australian biodiesel industry.
Australian Renewable Fuels Australian Biofuel Users, Inc. Axiom Energy Biodiesel Industries Australia Biodiesel Network Biodiesel Producers Biosel Cargill Eco-Tech Biodiesel Energetix (Smorgon Group) Ennfue Biodiesel Elders Freedom Fuels Gardner Smith Gull Petroleum Intertek Caleb Brett Laboratories Midfield Petroleum National Biodiesel Group Natural Fuels Australia Limited Pacific Biodiesel Riverina Biofuels Rockdale Beef The Biodiesel Station
We would further advise that a number of the above companies may have made individual submissions to the Department of the Environment and Heritage.
ATTACHMENT B
NFAL commissioned the Charles Darwin University to conduct an independent Demonstration Program of biodiesel over a six-month period in 2005/06, using B100 made from 90% palm oil and 10% soy oil meeting the European Standard for Biodiesel EN 14214 , imported from Spain. The cold filter plugging point (cfpp) was + 3 degrees C. The participants included buses from Darwin Bus Services, Darwin City Council vehicles, road trains, trucks, loading machinery, and light vehicles.
The Program showed for B100 reduced tailpipe emissions of –
and for Blend B20, reduced tailpipe emissions of
· up to 15% for carbon monoxide · up to 17% for total hydrocarbons · up to 23% for particulate matter (black soot) · up to 29% for exhaust smoke opacity
In addition, a 1.2% increase in fuel consumption for Blend B20 was recorded in dynamometer testing, but in road use, changes in fuel consumption attributable to using biodiesel were considered negligible. Participants were unable to detect any changes in the performance of the vehicle, with some drivers perceiving improved performance. No reliability issue in any of the trialled equipment was attributed to biodiesel use, lubricating oil sampling and analysis did not reveal any adverse effect on oil condition, viscosity, or engine condition, and no case of filter plugging due to biodiesel was encountered. The cfpp of the blend, using a control diesel with a cfpp of – 3 degrees C, was – 2 degrees C. No cfpp depressant additives were used. This reflects overseas experience wherein cold flow properties of blends up to B20 are largely influenced by the cold flow properties of the underlying petroleum diesel.
These results are the property of NFAL and are reprinted and presented with permission. |
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