Reviewing Aspects of the
Engine Fuel Specifications
Regulations 2008
Discussion Paper
December 2010
MED942608
The opinions and proposals contained in this document are for discussion purposes only
and do not necessarily reflect Government policy.
Readers are advised to seek specific legal advice from a qualified professional person
before undertaking any action in reliance on the contents of this publication. The contents
of this discussion paper must not be construed as legal advice. The Ministry of Economic
Development does not accept any responsibility or liability whatsoever whether in contract,
tort (including negligence), equity or otherwise for any action taken as a result of reading,
or reliance placed on the Ministry or because of having read any part, or all, of the
information in this discussion paper or for any error, inadequacy, deficiency, flaw in or
omission from the discussion paper.
Ministry of Economic Development
Energy and Communications Branch
33 Bowen Street
PO Box 1473
Wellington 6140
Tel: 04 472 0030
www.med.govt.nz
ISBN 978-0-478-35888-9 (PDF)
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Contents
MAKING A SUBMISSION.................................................................................................. 4
Posting and release of submissions ..................................................................... 4
Privacy.................................................................................................................. 4
1. INTRODUCTION ....................................................................................................... 5
1.1
Background................................................................................................ 5
1.2
Scope......................................................................................................... 5
2. SUMMARY OF PROPOSED CHANGES .......................................................................... 6
3. PETROL ................................................................................................................. 7
3.1
E70 minimum ............................................................................................. 7
3.2
Regular grade MON................................................................................... 9
3.3
Petrol/Ethanol blend waivers for VP......................................................... 10
3.4
Timing of introduction of zero sulphur petrol ............................................ 12
3.5
Manganese .............................................................................................. 13
4. ETHANOL ............................................................................................................. 15
4.1
Inorganic chloride limit and test methods ................................................. 15
5. DIESEL................................................................................................................. 17
5.1
Reduction of PAH maximum .................................................................... 17
5.2
Cetane index test method ........................................................................ 18
5.3
Density test method for diesel and biodiesel............................................ 19
5.4
“Alpine” diesel .......................................................................................... 19
5.5
A density waiver for diesel/biodiesel blends............................................. 20
6. BIODIESEL............................................................................................................ 22
6.1
Phosphorus limit and test methods .......................................................... 22
6.2
Test method for polyunsaturated methyl esters ....................................... 23
6.3
Adding a cold soak filterability test ........................................................... 23
7. OTHER ISSUES ...................................................................................................... 24
7.1
Definitions of petrol and diesel ................................................................. 24
7.2
Changes to Auckland local authority boundaries ..................................... 24
7.3
Footnote regarding seasonal overlap....................................................... 25
7.4
Provisions relating to biofuels and biofuel blends .................................... 26
8. SUMMARY OF QUESTIONS ..................................................................................... 27
GLOSSARY ................................................................................................................. 29
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Making a Submission
The Ministry is seeking comments on this discussion paper by 25 February 2011.
Questions are provided to assist, but general comments are also welcome. Where we
have asked for comment on an issue, we are particularly interested in the real or perceived
costs, benefits and risks of each proposal. Where possible and appropriate, please provide
quantified estimates of these costs, benefits and risks.
When making a submission, please include your name, organisation’s name (if
applicable), and your address (postal and/or email) and either:
send your comments by email, preferably in a Microsoft Word document, to
[email protected], or
mail a hard copy to:
Fuels and Crown Resources Group
Ministry of Economic Development
PO Box 1473
Wellington 6140
Posting and release of submissions
Written submissions may be posted at www.med.govt.nz/fuelspecs. We will consider
you to have consented to posting by making a submission, unless you clearly specify
otherwise in your submission. If sensitive material in your submission cannot be
published, please provide two versions of your submission – a full version and a
publishable version.
In any case, all information provided to the Ministry is subject to public release under the
Official Information Act 1982. Please advise if you have any objection to the release of
any information contained in a submission, and in particular, which part(s) you consider
should be withheld, together with the reason(s) for withholding the information. We will
take into account all such objections when responding to requests for copies and
information on submissions to this document under the Official Information Act 1982.
Privacy
The Privacy Act 1993 establishes certain principles with respect to the collection, use, and
disclosure of information about individuals by various agencies including the Ministry of
Economic Development. It governs access by individuals to information about themselves
held by agencies. Any personal information you supply in the course of making a
submission will be used by the Ministry only in conjunction with the matters covered by this
document. Please clearly indicate in your submission if you do not wish your name to be
included in any summary of submissions that we may publish.
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1. Introduction
1.1 Background
The Ministry of Economic Development (MED) is responsible for the administration of the
Engine Fuel Specifications Regulations 2008 (Regulations). The Regulations provide
comprehensive fuel specifications for petrol, petrol/ethanol blends, diesel, biodiesel and
diesel/biodiesel blends.
Most of the diesel used in New Zealand and a little over half of the petrol is supplied by the
New Zealand Refining Company Ltd (NZRC), with the remainder imported from refineries
around the Asia-Pacific. Most biofuels used are domestically produced.
The Regulations set out minimum standards affecting the performance of fuel, enabling
consumers to purchase petrol and diesel to a quality standard appropriate for New
Zealand’s vehicle fleet and climatic conditions. They also include provisions limiting
components that could be harmful to the environment or public health.
The current specifications are primarily the result of a major review undertaken in 2001/02
of the then Petroleum Products Specifications Regulations 1998.1 The outcomes of this
review and a subsequent review of sulphur levels were implemented between 2002 and
2009. Biofuels were added to the specifications in 2008 and ”engine fuel” replaced
“petroleum” in the name of Regulations at that time to reflect their broader scope.
The specifications provided in the Regulations reflect a continual balancing of costs and
benefits and have evolved in step with international developments in vehicle technology
and fuel supply.
Whilst there is much commonality amongst international fuel
specifications there is no international consensus on many parameters. It nonetheless
remains important that our specifications are aligned where possible with key sources of
vehicles and with fuel specification norms.
The tightening of fuel specifications over the last decade has reduced harmful emissions
from vehicles and enabled the uptake of the newest and cleanest vehicle technologies
(e.g. “Euro 5” diesel vehicles). Fuel that meets these tighter fuel specifications is however
more difficult to produce and only some refineries in the Asia-Pacific can achieve the
specifications consistently.
1.2 Scope
The focus of this review is on relaxing unnecessarily constraining fuel parameters,
reflecting technological advancements, aligning with overseas specifications, and future
proofing the regime. Specific proposals are outlined in this paper.
We are seeking information from stakeholders on the specific proposals and the questions
posed to inform decisions on changes to the Regulations. Feedback is also welcomed on
other aspects of the Regulations.
1
See the archive section of MED’s website at www.med.govt.nz/fuelspecs under the header Petrol and
Diesel: Delivering Quality for more information on this review.
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2. Summary of proposed changes
Petrol
•
Minimum E70 for summer season reduced from 22% to 20%
•
Minimum MON for regular grade petrol reduced from 82 to 81
•
Vapour pressure waiver of 7 kPa for petrol/ethanol blends extended to winter
season
Ethanol
•
Inorganic chloride content limit reduced from 32 mg/kg to 10 mg/kg
•
ASTM D 7319 and ASTM D 7328 prescribed as test methods for inorganic chloride
content
Diesel
•
Maximum PAH content reduced from 11% mass to 8% mass
•
ASTM 4737 prescribed in place of ASTM D 976 as the test method for cetane
index
•
ASTM D 4052 adopted as a test method for density as well as, or instead of, the
existing method (ASTM D 1298)
•
Density waiver for diesel/biodiesel blends up to 5% biodiesel of 0.002 kg/m3 (giving
a maximum density of 0.852 kg/m3)
Biodiesel
•
Maximum phosphorus content reduced from 10 mg/kg to 4 mg/kg
•
EN 15779 prescribed for measuring polyunsaturated methyl ester content
Other changes
•
Definitions of petrol and diesel amended to explicitly cover all fuels regardless of
the feedstock or production process
•
Definition of “Auckland and Northland” amended to reflect the southern boundary of
the new Auckland Council
•
Length of “grace period” for low volume filling stations to meet seasonal transitions
defined
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3. Petrol
3.1 E70 minimum
What is E70?
E70 refers to the percentage by volume of petrol that evaporates when heated to 70
degrees Celsius (°C). E70 is one of a number of specified parameters through which petrol
volatility is controlled. The others are E100 (percentage of petrol that evaporates at 100
°C), E150, end point (the point at which all volatile components have burned off), vapour
pressure (VP) and flexible volatility index (FVI).2 E70 relates predominately to cold running
performance.
What is the current specification?
The Regulations specify a minimum E70 of 22% and a maximum of 48%. This
specification applies in all regions and in all seasons to both regular and premium grade
petrol.
What is the issue?
E70 is a constraining parameter for fuel suppliers, particularly for premium grade petrol
(petrol with a research octane number (RON) of 95 or higher) in summer3. This section
discusses whether a reduction in minimum E70 is appropriate, and if so to what extent.
Meeting other regulated parameters (most notably octane and VP) can adversely impact
E70 values in petrol. For instance, higher octane levels in petrol can be achieved through
high aromatics composition and other heavier components, but this leads to low E70
values. Keeping VP low requires limiting the volatile components and this also leads to
low E70 values.
Whilst there are good policy reasons for each of the individual VP, E70 and octane
parameters, tight specifications for all three creates a very narrow acceptable range at
certain times. This is most acute in regard to higher octane premium grade petrol for the
Auckland/Northland summer specification where the strictest VP maximum of 65 kPa
applies. The narrow range resulting from this makes producing acceptable product
challenging, potentially increasing costs and sometimes delays while re-blending occurs.
The minimum octane for premium grade of 95 RON is a standard international
specification for vehicles and fuel and so no consideration is being given to changing this.
The strict summer VP limit of 65 kPa was deliberately imposed for the Auckland/Northland
region as evaporative hydrocarbon emissions are an air quality concern in Auckland. Of
the three constraining parameters it is therefore the specified E70 minimum which appears
worthy of further consideration. In particular we are considering whether a minimum E70
2
Vapour pressure (VP) is a measure of the volatility of a liquid fuel measured at standardised
temperature and pressure. E70 is the percentage by volume of petrol that has evaporated when it is heated
to 70°C. Flexible Volatility Index (FVI) is a function of VP and E70. VP and E70 are good measures of cold
running performance in vehicles whereas FVI is a good measure of hot running performance.
3
The summer season for petrol is the period 1 December to 31 March (inclusive).
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requirement of 22% remains necessary at all times as even a minor relaxation to 20%
minimum would appear sufficient to ease the constraint outlined above.
The potential adverse impact that has been identified with reducing the minimum E70
would be on the cold starting and cold running performance of some engines, in particular
those fitted with carburettors. Until 1994 the minimum specified value for E70 was 15%.
This was increased to 25% in 1994 after several cases of cold starting difficulties and then
relaxed to 22% in 2002 following the comprehensive review of the specifications. The
composition of New Zealand’s vehicle fleet has changed significantly since 1994, with
carburettor-equipped engines now representing a much smaller proportion of the fleet.
For those petrol specifications around the world that specify E70 limits a minimum of 20%
to 22% is usual for climates similar to New Zealand’s. Based on research4 undertaken in
the late 1990’s, the European petrol specification (EN 228) prescribes different classes of
volatility parameters (e.g. VP and E70) for different climatic conditions. Those classes
relevant to New Zealand summer conditions (classes A and B) have a minimum E70 of
20% while those more relevant to winter conditions have a minimum E70 of 22%. Volatility
classes prescribed in the Worldwide Fuel Charter5 (WWFC) for climates with temperatures
above 5°C (also A and B) provide a minimum E70 of 20% as well, with higher E70 values
for temperatures below 5°C.
Other parameters that contribute to good drivability such as minimum VP, E100 and FVI
would remain unaltered if any change was made to E70. Given this and the high
proportion of fuel injected vehicles in the vehicle fleet, the likelihood of vehicle
performance being adversely impacted by an E70 value below 22% appears fairly low.
The scale of any impact also appears small, with cold starting difficulties most likely.
Three options for amending the E70 specification to address the issue identified are
outlined in the following table, in order from least to greatest extent of change.
Option 1
Reduce E70 to 20% for
premium grade in summer in
Auckland/Northland only
This would ease the most acute supply constraint whilst
also limiting the possible impact on vehicle operability by
only making a change in the region and season where it
would be least likely to have an impact.
Option 2
Reduce E70 to 20% for all
petrol in summer season
A wider reduction of minimum E70 in summer for all petrol
to 20% would give greater supply flexibility for both grades
and maintain a consistent specification for this parameter
for all petrol.
Option 3
Reduce E70 to 20% for all
petrol in all seasons
This would maximise supply flexibility but would carry a
greater risk of vehicle operability issues by including the
colder times of year.
4
See CONCAWE report no. 99/51, “Proposal for revision of volatility classes in EN 228 specification in light
of EU fuels directive”, January 1999.
5
WWFC is a set of recommendations for unleaded petrol and diesel specifications, produced by a group of
four international automotive manufacturing associations.
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On balance Option 2 is proposed (minimum E70 for petrol in summer reduced from 22% to
20%). We consider this option would give clear supply benefits whilst carrying little, if any
risk, of adverse vehicle performance.
Q1
Do you agree that the minimum E70 requirement in summer should be
changed from 22% to 20% for petrol?
3.2 Regular grade MON
What is MON?
Octane number is a measure of petrol fuel’s resistance to auto-ignition. Auto ignition in
petrol engines can be classified into two types:
ƒ
Knock – caused by spontaneous combustion of a portion of un-burnt air/fuel mixture
ahead of the advancing flame front.
ƒ
Surface ignition – where ignition is initiated by any hot surface in the combustion
chamber rather than spark discharge at the spark plug.
Spark ignition (i.e. petrol) engines are designed for a certain minimum octane rating.
Using a fuel of a lower octane rating may result in knocking or surface ignition and in some
circumstances can cause engine damage. Using a fuel of a higher octane rating than
required does not generally improve engine performance. The required octane for a
particular engine can change over the life of the engine, for example due to the build up of
deposits. Many modern vehicles have “knock sensors”, which can adjust engine operation
to compensate for insufficient octane.
Octane levels can be represented either through RON or minimum motor octane number
(MON). MON reflects the anti-knock performance of fuel under high engine speed and
higher load conditions. At high loads detonation problems can be inaudible and therefore
unnoticed by most drivers, increasing the risk of engine damage. Insufficient MON is
therefore a particular problem in high load conditions in vehicles that do not possess knock
sensors.
What is the current specification?
New Zealand’s regulated minimum MON for regular grade petrol is 82 (minimum RON is
91). For those vehicle requiring higher octane petrol there is premium grade (95 RON/85
MON minimum).
What is the issue?
Our minimum MON requirement of 82 for regular grade is higher than in a number of
relevant jurisdictions of vehicle and fuel supply. As a higher MON level increases fuel
supply costs, and delivers no benefits to engines that don’t require it, the continuing
appropriateness of this specification appears worthy of reconsideration. This issue was
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considered in 2005 but no changes were made at that time.6 Views received were mixed
on the comparative merits of an 81 or 82 MON limit.
International specifications and standards for MON are relevant as they reflect both vehicle
operability requirements and available fuel supplies. There is however no international
consensus on minimum MON requirements and many jurisdictions do not actually specify
a separate MON parameter, relying simply on a RON requirement or a combined octane
value (RON + MON divided by 2).
Australia and Europe (EN 2287) specify a minimum MON of 81 for regular grade. The
North American markets require 82 MON but are not a large source of vehicles or fuel for
New Zealand. Our largest source of vehicles, Japan, does not specify a minimum MON
for its low octane 89 RON grade and neither does South Korea for its 91 RON petrol. The
WWFC provides a minimum MON of 82.5 for regular grade. The fact that most of New
Zealand’s vehicles are sourced from, or sold in, the Japanese and Australian markets
where regular grade MON is not regulated above 81 minimum suggests that this should be
sufficient for most vehicles.
As noted above, producing or sourcing higher octane petrol is generally more costly. The
need to meet the 82 MON requirement for regular grade petrol can necessitate sourcing
fuel with a RON of 92 or 93 rather than 91, which has cost implications. We note however
that the current specification for regular grade includes limits for several other parameters
(olefins, MTBE, aromatics) which already mean it is considered high quality, and therefore
more expensive than typical regular grade petrol produced in the Asia-Pacific region.
Given NZRC’s configuration, a reduction in regulated MON would not be expected to
impact its production of petrol significantly.
It is proposed that MON for regular grade petrol be reduced from 82 to 81.
Q2
Do you agree that the minimum MON requirement for regular grade petrol
should be reduced from 82 to 81?
3.3 Petrol/Ethanol blend waivers for VP
What is VP?
As outlined above in section 3.1 vapour pressure (VP) is a measure of the volatility of
petrol and relates to the lighter components in the fuel such as butane. It is defined as the
absolute VP exerted by a liquid at 37.8 °C.
What is the current specification?
Schedule 1 of the Regulations provides a minimum VP of 45 kPa and a range of maximum
VP limits for petrol that vary by region and season from 65 to 95 kPa.
6
Cabinet Paper: Changes to the Petroleum Products Specifications Regulations 2002, see:
http://www.med.govt.nz/templates/MultipageDocumentPage____21706.aspx
7
EN 228:2008 - Automotive fuels. Unleaded petrol. Requirements and test methods
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To facilitate the distribution of petrol/ethanol blends containing up to 10% ethanol the
following specification “waivers” for these blends were introduced in 20078:
•
VP: 7 kPa for summer and transition seasons (not for winter);
•
E70: increase maximum by 1% per % of ethanol; and
•
FVI: increase by 5 in transition seasons and by 15 in winter.
The waiver of 7 kPa for VP recognises that blending ethanol into petrol causes an increase
in VP and was determined following a technical analysis undertaken in 2006.9
What is the issue?
Without the waivers of those properties noted above the supply of ethanol blends in New
Zealand would likely require a special petrol blendstock, which would make it more difficult
and costly to supply such blends.
Fuel suppliers have raised questions about the comprehensiveness of these waivers –
particularly the absence of a VP waiver for winter. Whilst investigations in 2006 concluded
a waiver for VP in winter is not generally needed, not having one acts as a constraint –
especially for premium grade blends. Although most blends of ethanol with standard
winter petrol would not require a waiver, the fact that a small number might makes
consistently supplying an on-spec blend all year using standard petrol potentially
impossible. This could act as a barrier to the distribution of biofuels in New Zealand. The
benefit of extending the VP waiver to winter would be to allow fuel suppliers to blend
ethanol into standard petrol all year without the risk of exceeding VP requirements.
The adverse consequence of extending the VP waiver to include winter would be a small
increase in evaporative emissions in winter from any fuel that took advantage of the
waiver. Given the lower temperatures prevailing in winter, the fact that only a small
number of blends would likely take advantage of the waiver, and the currently low
penetration of petrol/ethanol blends, any increase in evaporative emissions is likely to be
minor. The change is not expected to have any adverse impacts on vehicle operability as
all other distillation parameters would remain unchanged.
In the interests of removing any unnecessary impediments to the supply of biofuels in New
Zealand we consider that on balance extending the 7 kPa VP waiver for petrol/ethanol
blends to include VP in winter has merit. Implementing this proposal result in a consistent
set of waivers for all seasons.
The blend waivers for VP, E70 and FVI have now been in place for three years. Officials
are welcoming wider feedback on the waivers, including those for E70 and FVI. In
particular whether they are sufficiently comprehensive to avoid unnecessary constraints on
the supply of petrol/ethanol blends.
8
Cabinet Paper - Petroleum Products Specifications Regulations: Biofuel Blend Waivers and Amendments
to the Diesel Carbon Residue Property, see:
http://www.med.govt.nz/templates/MultipageDocumentTOC____25328.aspx
9
Investigation of Fuel Specification Waivers for Biofuel Blends, September 2006, see:
http://www.med.govt.nz/templates/MultipageDocumentTOC____22711.aspx
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Q3
Do you agree with the proposal to extend the current 7 kPa VP waiver for
summer and transition seasons to include winter?
Q4
Is any further extension of the waivers for VP, E70 and FVI necessary to
facilitate the supply of petrol/ethanol blends?
3.4 Timing of introduction of zero sulphur petrol
What is sulphur?
Sulphur occurs naturally in crude oils and must be removed to an acceptable level during
the refining process as it promotes corrosion and affects the performance of vehicle
emissions control equipment.
What is the current specification?
The current maximum sulphur limit for both regular and premium grade petrol is 50 mg/kg,
which is referred to in this paper as 50 parts per million (ppm).
What is the issue?
It has been signalled since the 2001 – 2002 review that the maximum permitted level for
petrol would ultimately be further reduced to 10 ppm, which is often referred to as “sulphur
free” petrol. It was previously thought here and in Australia that a date around 2010 would
be an appropriate introduction date for zero sulphur petrol.10
The current 50 ppm sulphur limit supports the current New Zealand vehicle emissions
standard requirements for new petrol vehicles of Euro 4.11 The subsequent Euro 5
emissions standard for petrol vehicles requires 10 ppm sulphur maximum petrol. A date
for the adoption of this standard has yet to be fixed in New Zealand or Australia.
The technical rationale identified for reducing maximum permitted sulphur levels to 10 ppm
is to support emissions control technologies such as “NOx traps” fitted to some modern
vehicles. The extent to which such vehicles require a 10 ppm sulphur petrol, or whether it
would simply improve their performance or long term durability vis-à-vis a 50 ppm petrol, is
unclear. The benefits for other vehicles would be minor.
The actual sulphur content of petrol supplied in New Zealand is generally well below the
current limit of 50 ppm. Some samples taken are below 10 ppm and most are under 40
ppm. This is largely because the platformer used at the Marsden Point Refinery to
upgrade naphtha to high octane gasoline blendstocks requires the sulphur in the feed to
be removed before processing. Imported petrol, which comes from a number of different
refineries, tends to vary more in sulphur level.
10
Review of Permitted Sulphur Levels Beyond 2006 under the Petroleum Products Specifications
Regulations, Ministry of Economic Development (2005), see
http://www.med.govt.nz/templates/MultipageDocumentTOC____10378.aspx
11
Land Transport Rule: Vehicle Exhaust Emissions 2007, see
http://www.nzta.govt.nz/resources/rules/vehicle-exhaust-emissions-2007-index.html
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The only countries in the Asia-Pacific region to have adopted a 10 ppm sulphur limit for
petrol are Japan and South Korea. Australia has a 50 ppm limit for Premium and a higher
150 ppm limit for regular grade petrol. Other major fuel markets in the Asia-Pacific region
currently have limits of 50 ppm or 500 ppm, with Taiwan scheduled to introduce a 10 ppm
limit from 2012. Adopting a 10 ppm limit for petrol at this time would move New Zealand
ahead of most of the Asia-Pacific region.
Notwithstanding the generally low sulphur levels of petrol in the New Zealand market,
regulating a 10 ppm maximum would likely reduce regional supply options and have cost
implications for fuel suppliers. We also note that the additional processing required to
consistently meet a 10 ppm limit can also increase energy demands and CO2 emissions at
refineries.
Whilst it still appears that the adoption of a 10 ppm sulphur limit will ultimately be
necessary to support some vehicle technologies, the timing and scope of this move (i.e.
premium grade only or both grades) needs to be considered in cognisance of vehicle
technology demands and fuel supply availability and costs. Moving to a 10 ppm limit
earlier than appropriate would impose costs on all suppliers and ultimately consumers,
whilst yielding few if any reductions in harmful emissions or other benefits.
Whilst a consistent 50 ppm sulphur limit for both grades was adopted in New Zealand,
officials recognise that depending on vehicle requirements, a split approach between
grades may be appropriate for the adoption of a 10 ppm limit. This could facilitate the
importation of the latest vehicle technologies, which generally use higher octane premium
grade, whilst avoiding any adverse cost or supply implications for regular grade.
No reduction in regulated petrol sulphur levels is proposed at this time.
Q5
Do you agree that no further reduction in petrol sulphur is appropriate at this
time?
Q6
When is it likely that 10 ppm sulphur petrol will be required by vehicles and
will it be necessary for both grades of petrol?
3.5 Manganese
What is Manganese?
Methylcyclopentadienyl manganese tricarbonyl (MMT) is a manganese-based compound
used as an octane-enhancing fuel additive for petrol (typically in concentrations up to 18
mg/litre).
What is the current specification?
Schedule 1 of the Regulations provides for a maximum manganese limit of 2 mg/litre in
petrol as tested by ASTM D 3831.
There is no approval under the Hazardous Substances and New Organisms (HSNO) Act
1996 for petrol to contain MMT. Such an approval would be needed before MMT could be
legally incorporated in petrol in New Zealand (this applies to both domestically produced
and imported petrol).
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What is the issue?
There has been a long running international debate regarding the use of MMT as a fuel
additive that has centred on its potentially adverse effects on engine operability and
human health.
A precautionary approach was taken in New Zealand with regard to the limit imposed on
manganese content.12 The Petroleum Products Specifications Regulations 2002 provided
that the limit on manganese would be reviewed in 2006. The issue was duly considered in
2006, and it was decided that the regulated manganese limit should remain until such time
that there is sufficient information from reviews of the health and vehicle impacts of
manganese in petrol.13
There have been recent international developments with regard to manganese. The 2009
European Fuel Quality Directive14 provides that MMT in fuel shall be limited to 6 mg of
manganese per litre from 1 January 2011 and 2 mg of manganese per litre from 2014. It
outlines that the Commission shall conduct an assessment of the risks for health and the
environment from the use of metallic additives in fuel and, for this purpose, develop a test
methodology. It shall report its conclusions to the European Parliament and to the Council
by 31 December 2012. The directive also requires labelling at point of sale where metallic
additives are used.
We are not aware of any conclusive information to suggest a change to the current
approach to manganese content.
Q7
Do you agree with the proposal to maintain the status quo with regard to
manganese content?
12
See section 7.13 of Petrol and Diesel: Delivering Quality, September 2001,
http://www.med.govt.nz/templates/ContentTopicSummary____16642.aspx
13
Cabinet Paper: Changes to the Petroleum Products Specifications Regulations 2002, see:
http://www.med.govt.nz/templates/MultipageDocumentPage____21703.aspx
14
Directive 2009/30/EC of the European Parliament, 23 April 2009
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4. Ethanol
4.1 Inorganic chloride limit and test methods
What is inorganic chloride?
Ethanol can be contaminated with chloride ions that can form plugging deposits and can
cause corrosion in engines, even at very low levels.
What is the current specification?
Currently the inorganic chloride limit for ethanol specified in Schedule 4 of the Regulations
is 32 mg/litre. The specified test method for inorganic chloride is “ASTM D512-81 (1985),
Method C (as modified in ASTM D4806)”.
What are the issues?
When introduced the current limit on inorganic chloride was consistent with the Australian
and ASTM specifications for ethanol. Recent international developments suggest that a
lower minimum level could be appropriate and that new test methods could be adopted.
The WWFC’s 2008 ethanol specification, and the most recent version of the ASTM ethanol
specification (D 4806-09) both prescribe a 10 mg/litre maximum for inorganic chloride
content. The European ethanol specification (EN 15376:2007) has a 20 mg/litre limit for
inorganic chloride content (relevant to petrol/ethanol blends of up to 5% rather than 10%)
and the Brazilian specification effectively limits inorganic chloride content to 1 mg/litre.
We are proposing that the limit for inorganic chloride in the Regulations be reduced from
32 mg/litre to 10 mg/litre to more closely align with international specifications. This will
provide greater protection for engines and fuel systems against the potentially corrosive
effects of inorganic chlorides. The proposed change is not expected to greatly impact
ethanol producers and suppliers as inorganic chloride content in ethanol should be low.
Given that the test method for inorganic chloride content prescribed in the Regulations is
no longer included in the latest version of ASTM D 4806 and that suitable test methods
exist, we are also proposing changes to the test method. ASTM D 7319 and 7328 are
both suitable for measuring inorganic chloride content and are already prescribed in the
Regulations for testing sulphate content. The latest version of ASTM D 480615 and the
WWFC both specify these two methods for measuring inorganic chloride content.
15
ASTM D 4806-09 Standard Specification for Denatured Fuel Ethanol for Blending with Gasolines for Use
as Automotive Spark-Ignition Engine Fuel
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We propose adopting these two methods (ASTM D 7319 and D 7328) for measuring
inorganic chloride content. This would align with recent international developments and
should minimise testing costs by allowing a single method to be used for multiple
parameters.
Q8
Do you agree with reducing the maximum permitted inorganic chloride
content from 32 mg/litre to 10 mg/litre?
Q9
Do you agree with prescribing ASTM D 7319 and ASTM D 7328 as test
methods for inorganic chloride in place of the currently prescribed method?
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5. Diesel
5.1 Reduction of PAH maximum
What is PAH?
Aromatics containing multiple benzene rings are known as polycyclic aromatic
hydrocarbons (PAHs). PAHs contribute to various harmful emissions and some are
known to be carcinogenic. PAHs are predominantly present in the heavier ends of diesel
and so their content is controlled to some extent through the distillation parameters such
as T95.
What is the current specification?
The limit on PAHs in diesel is 11% by mass. This limit was determined in 2002 and came
into effect in 2006.
What is the issue?
Higher PAH content can increase some types of harmful emissions (e.g. particulates and
PAH emissions) and so minimising PAH content contributes to improving air quality. The
current level of PAHs in diesel supplied in New Zealand is well below the regulated
maximum, with an average content of around 3% and only a small proportion of diesel
above 5% PAH. Reducing the current limit would align with some recent international
developments and ensure that PAH levels remain low in practice.
The current regulated limit of 11% maximum was aligned with the limits applying in Europe
and Australia at the time it was introduced and a number of other jurisdictions in the AsiaPacific region also specify an 11% maximum. The European limit has however recently
been reduced to 8% maximum as specified in EN 59016. Some jurisdictions such as
California and South Korea have stricter limits of 5% or less on PAH content. The WWFC
specifies varying limits on PAH content of between 5% and 2% for those markets requiring
emissions control technologies.
We are proposing the adoption of an 8% limit for PAH content as this would align with the
European diesel standard and ensure the PAH content of diesel supplied in New Zealand
remains low. Given current diesel supplies it does not appear that this tighter limit would
constrain diesel supply options in practice. It would nonetheless make New Zealand’s
diesel specification tighter than the Australian specification of 11% and that of a number of
other jurisdictions in the Asia-Pacific.
Q10 Do you agree with reducing maximum diesel PAH content from 11% mass to
8% mass?
16
EN 590:2009 Automotive fuels. Diesel. Requirements and test methods
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5.2 Cetane index test method
What is cetane index?
Cetane is a measure of diesel’s propensity for autoignition. The cetane number is
measured using a cetane test engine. Cetane index is an estimation of the cetane number
calculated from distillation data and density. As there are very few test engines in
existence, cetane index is commonly used around the world with many diesel
specifications providing for both cetane number and cetane index.
What is the current specification?
Schedule 2 of the Regulations provides parameters and test methods for both cetane
number and cetane index for diesel. ASTM D 976 is the specified test method for cetane
index.
What is the issue?
Work carried out by the Ministry in the late 1990’s on correlations between cetane index
(as determined by the methods ASTM D 976 and ASTM D 4737) and measured cetane
number suggested that D 976 provided a better correlation for New Zealand fuels at the
time.17 Since 2002 changes in fuel specifications and the configuration of refineries,
including NZRC, have led to significant changes in the composition of diesel supplied in
New Zealand.
ASTM D 4737 is now more commonly used internationally. It is the method prescribed for
cetane index in the Australian diesel specification, and the WWFC. The test method EN
ISO 4264:2007, which is identical in its method and calculation to ASTM D 4737, is
specified in the European Diesel specification (EN 590). To align with international
practice it is proposed that ASTM D 4737 be specified in place of ASTM D 976 in
Schedule 2 of the Regulations.
Q11 Do you agree with the proposal to adopt ASTM D 4737, in place of ASTM D
976, as the test method for cetane index?
17
Cetane Number of New Zealand Diesel, April 1999, see:
http://www.med.govt.nz/templates/MultipageDocumentTOC____8363.aspx
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5.3 Density test method for diesel and biodiesel
The test method ASTM D 1298 is currently the only method specified in the Regulations
for measuring the density of diesel and biodiesel. The method ASTM D 4052 is also
applicable to the measurement of density and is used commonly internationally. It is
proposed that ASTM D 4052 be prescribed in addition to the existing method.
Q12 Do you agree that ASTM D 4052 should be adopted as a test method for
density?
Q13 Is it necessary to retain the existing method (ASTM D 1298) as a test method
for density?
5.4 “Alpine” diesel
Diesel contains parafins which will start to form wax crystals as the fuel is cooled. This can
lead to blockages of fuel filters and interruption to fuel supply under cold conditions.
Sustained periods of cold weather tend to be most problematic.
The diesel specification controls cold weather diesel performance through both cloud point
and Cold Filter Plugging Point (CFPP). Cloud point is the temperature at which wax
crystals start to precipitate out and the fuel becomes cloudy. CFPP is the lowest
temperature at which the fuel can pass through a standard test filter under standard
conditions. CFPP is more precise than cloud point and generally provides a better
indication of fuel performance in an engine.
The Regulations minimum requirements for winter are +2°C cloud point and -6°C CFPP.
Fuel suppliers however supply diesel with superior properties (up to -15°C CFPP) in colder
regions in winter to ensure fitness for purpose. Some fuel suppliers have also supplied
diesel with a CFPP below -15°C to some users operating in the coldest areas of New
Zealand (for example ski fields).
Supplying diesel with particularly good cold properties to some customers in cold areas
was traditionally done through blending kerosene with diesel. Given that this fuel is
supplied on a non-retail basis it is required by clause 15 of the Regulations to conform only
to the specifications for sulphur and PAHs specified in Schedule 2. We note a separate
HSNO approval is provided for this diesel because the increased kerosene content tends
to result in a low flashpoint.18
The adoption from 2009 of a 10 ppm sulphur limit for all diesel (both retail and non-retail
with the exception of diesel supplied for marine use) effectively precluded the use of any
diesel blend component with a sulphur level above 10 ppm. The kerosene available at fuel
terminals around New Zealand is jet fuel and generally has a sulphur level between 100
ppm and 500 ppm (although sulphur content in jet fuel is allowed up to 3000 ppm under
the international Jet A-1 specification). The 2009 sulphur level reduction therefore
precluded the blending of available kerosene with diesel.
18
Low flashpoint diesel (low flash domestic heating oil and alpine diesel), see:
http://ermanz.govt.nz/appfiles/OrgCtrl/pdf/HSR001447Con.pdf
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Fuel suppliers could source very low sulphur kerosene for blending with diesel, however
given the small volumes involved it is unclear the extent to which this approach is practical.
Officials are seeking feedback on whether there is a need to amend the Regulations to
allow the post-refinery blending of widely available but higher sulphur kerosene with diesel
to create a diesel with particularly good cold performance.
Allowing a higher sulphur content for some diesel would increase harmful emissions such
as particulates from diesel engines that used this fuel. A higher sulphur level could also
have a potentially serious and irreparable impact on the emissions control equipment fitted
to many modern diesel engines. Accordingly the use of any diesel containing more than
10 ppm sulphur would have to be limited to suitable engines, which would mean supply on
a non-retail basis only where a contract exists between fuel supplier and customer.
Blending kerosene also tends to reduce the cetane and lubricity of the fuel. Whilst these
two parameters are not regulated for non-retail supplies they would need to be maintained
by suppliers to ensure fitness for purpose.
Should a further exception to the 10 ppm sulphur limit for diesel be permitted, in addition to
the existing exception for marine diesel, it would be sensible that it be defined as narrowly
as possible. We envisage it would at minimum be limited to non-retail sale in winter and
that further conditions would also likely be appropriate. Feedback is sought on the need
for post-refinery blending of kerosene with diesel to create a fuel with particularly good
cold properties for our colder areas.
Q14 Is there a need to facilitate the post-refinery blending of kerosene with diesel
to create a fuel with particularly good cold properties for our colder areas. If
so in what circumstances would it be required?
5.5
A density waiver for diesel/biodiesel blends
The density of any diesel (including that containing up to 5% biodiesel) supplied for retail
sale must be between 820 kg/m3 and 850 kg/m3. The density of diesel is controlled within
a range so as to optimise engine performance and control exhaust emissions.
Biodiesel meeting the Regulations specification for biodiesel has a higher density (860 –
900 kg/m3) than diesel (820 – 850 kg/m3). Density follows a linear equation and so it is
possible to determine the resultant density from a diesel/biodiesel blend if the density of
the two components and the blend concentration is known.
If biodiesel is blended with diesel at the top of the density range (i.e. 850 kg/m3) then the
resulting blend would be off-specification even though both individual blend components
met their respective specifications. Should a fuel supplier intend to consistently include
biodiesel in their retailed diesel they would have to ensure that the diesel component was
not at the top of the density range (i.e. above 847 kg/m3) or reduce the biodiesel content to
as little as 1% when diesel density was high. Avoiding the top of the diesel density range
at all times would be an additional constraint that could be impractical or have cost
implications.
An alternative approach would be to provide a waiver that recognised that blending two
on-spec components could yield a product with a density above the top of the prescribed
range. Because of the different nature of biodiesel (e.g. no aromatics and oxygen content)
it generally burns more leanly than diesel and therefore a higher density blend would not
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necessarily impact engine performance and emissions in the way a high density diesel
could. The higher density content would be due to the presence of fatty acid methyl esters
(FAME) rather than heavy molecular weight hydrocarbons.
Consideration was given in 2007 to providing a density waiver for diesel with up to 5%
biodiesel of 0.002 kg/m3 (giving a maximum density of 0.852 kg/m3).19 Stakeholder
feedback on the need for this was mixed and it was determined that because it would only
be required in a very small proportion of situations (about 1%) the benefits of it would be
outweighed by the administrative complications and costs.20
Since 2007 domestic experience in biodiesel production and supply of blends has
increased and so feedback is again sought on whether consideration should be given to
providing a small density wavier (around 0.002 kg/m3) for diesel containing up to 5%
biodiesel. The advantage would be to simplify the supply of diesel/biodiesel blends.
Disadvantages include inconsistency with approaches in some international jurisdictions
(e.g. Europe) and possible impacts on engine fuelling.
Q15 Do you agree that a density waiver for diesel/biodiesel blends up to 5%
biodiesel of 0.002 kg/m3 (giving a maximum density of 0.852 kg/m3) should
be introduced?
19
Fuel Specifications - Biofuel Blends Waivers Discussion Document, see:
http://www.med.govt.nz/templates/MultipageDocumentTOC____22707.aspx
20
Cabinet Paper - Petroleum Products Specifications Regulations: Biofuel Blend Waivers and Amendments
to the Diesel Carbon Residue Property, see:
http://www.med.govt.nz/templates/MultipageDocumentTOC____25328.aspx
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6. Biodiesel
6.1 Phosphorus limit and test methods
What is phosphorus?
Phosphorus can be present in biodiesel at low levels as a result of compounds naturally
found in biodiesel feedstocks.
What is the current specification?
The current maximum limit on phosphorus for biodiesel is 10 mg/kg. The specified test
method is ASTM D 4951.
What is the issue?
Phosphorus can damage the ability of after-treatment systems to reduce harmful exhaust
emissions. The effect of phosphorus is cumulative and so very low levels of contamination
over the significant amount of fuel consumed by an engine may lead to deterioration of
emissions control systems.
The limit on phosphorus of 10 mg/kg provided in the Regulations was consistent with
international best practice when it was set in 2008. Subsequent international
developments suggest however that a stricter limit may be appropriate.
The limit for phosphorus has recently been reduced in the European biodiesel standard
(EN 14214) from 10 mg/kg to 4 mg/kg. The WWFC’s B100 specification also provides a
limit of 4 mg/kg and states that an even lower limit might be adopted if better test methods
become available. We propose that to align with international best practice the limit for
phosphorus in biodiesel specified in the Regulations should be reduced to 4 mg/kg.
In addition to reducing the limit on phosphorus it is proposed that the test method EN
14107 be adopted for measuring phosphorus content in biodiesel in place of the current
method (ASTM D 4951).
Q16 Do you agree with reducing the limit on phosphorus for biodiesel from 10
mg/kg to 4 mg/kg?
Q17 Do you agree with adopting the test method EN 14107 for measuring
phosphorus content in biodiesel in place of the currently specified method?
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6.2 Test method for polyunsaturated methyl esters
There is no method currently prescribed for measuring polyunsaturated (≥4 double bonds)
methyl esters. This reflected the absence of an appropriate test method when the
Regulations were promulgated in 2008 and this gap exists in other biodiesel specifications.
In 2009 a method (EN 1577921) for measuring polyunsaturated methyl esters was finalised
and it is proposed that this is adopted in the Regulations.
Q18 Do you agree with adopting the test method EN 15779 for measuring
polyunsaturated methyl ester content in biodiesel?
6.3 Adding a cold soak filterability test
The cold performance of biodiesel is related to both the feedstock used and the quality of
processing. Specific cold performance parameters are not provided in the Regulations for
biodiesel but retailed diesel/biodiesel blends must meet the limits on cloud point and CFPP
provided in Schedule 2 and all fuel supplied must be fit for common purposes.
The “total contamination” test prescribed in the Regulations (IP 440) characterises the
filtration properties of biodiesel but is not focussed on its filterability in cold conditions.
In response to concerns with the cold performance of biodiesel in America a cold soak
filtration test was added from April 2009 to the mandatory annex in the ASTM biodiesel
specification D 6751. Cold soak filtration analysis is defined as: the time in seconds that it
takes for cold soaked biodiesel to pass through two 0.8 micron filters and the amount of
particulate matter expressed in milligrams per litre collected on the filter.
An updated cold soak filtration test was subsequently developed by the ASTM – “D 750109b Standard Test Method for Determination of Fuel Filter Blocking Potential of Biodiesel
(B100) Blend Stock by Cold Soak Filtration Test”. This method is not explicitly feedstock
specific and its scope suggests that it could be suitable for inclusion in New Zealand’s
biodiesel specification. We are aware that questions have been raised in relation to some
aspects of this new method, such as its reproducibility and its applicability to all
feedstocks.
There appears to be merit in introducing a parameter that directly considers the cold flow
filterability of biodiesel, however, only if there is a suitable test method available. Officials
seek feedback on this proposal and whether any recently developed test methods would
be suitable to New Zealand circumstances and feedstocks.
Q19 Do you agree there is a need to introduce a parameter for biodiesel relating
to cold soak filterability?
Q20 If a parameter for cold soak filterability was to be included, would the test
method ASTM D 7501-09b be suitable? If not is there any other method that
would be more suitable?
21
EN 15779:2009, determination of polyunsaturated (≥ 4 double bonds) fatty acid methyl esters by gas
chromatography.
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7. Other issues
7.1 Definitions of petrol and diesel
The definitions of petrol and diesel in the Regulations cater to traditional fuels that are
refined from crude oil. It is likely however that over time a portion of New Zealand’s liquid
fuel will be sourced from ‘non traditional sources’. This view is based on domestic
precedents (e.g. synthetic petrol was produced at Motunui in the 1980’s and 90’s), recent
domestic announcements around the possibility of utilising lignite to produce transport
fuels, and prominent international examples of coal-to-liquids (CTL), gas-to-liquids (GTL)
and biomass-to-liquids (BTL) production.
All these various methods can produce hydrocarbon fuels that are fungible with traditional
refined fuels. It is proposed that the definitions of petrol and diesel be amended so as to
explicitly cover all relevant fuels regardless of the feedstock or production process
employed to produce them.
We note that in some cases synthetic fuels, particularly synthetic diesels can have
different chemical properties to traditional fuels. For example synthetic diesel fuel can
have higher cetane than conventional diesel but lower density. It is not proposed at this
stage that any allowances be made for the potentially different nature of some synthetic
fuels.
Q21 Do you have any comments on the proposal to amend the definitions of
petrol and diesel?
7.2 Changes to Auckland local authority boundaries
Some of the petrol and diesel specifications vary by season and region. The northernmost
region “Auckland and Northland” is defined in the Regulations as “the area contained
within the Auckland Regional Council and Northland Regional Council boundaries”. All
other fuel deliveries in the North Island are classified as the “rest of North Island”.
The southern boundary of the new Auckland Council is slightly different to the former
southern boundary of the current Auckland Regional Council.22 We propose that the
Regulations be updated to refer to the southern boundary of the Auckland Council. This
change would only impact any filling stations or fuel deliveries that changed region in
terms of the Regulations as a consequence of this.
Q22 Do you have any comments on updating the definition of “Auckland and
Northland” to include the southern boundary of the new Auckland Council?
22
Maps are available from:
http://www.lgc.govt.nz/lgcwebsite.nsf/wpg_URL/Auckland-Governance-Index!OpenDocument
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7.3 Footnote regarding seasonal overlap
The Regulations contain seasonal specific, permissible limits on certain fuel parameters.
Fuel suppliers are required to manage the transitions between seasons so that fuel being
supplied remains on-spec to the relevant season at all times. This is an issue where the
specification from season to season becomes tighter.
As completely emptying tanks before refilling them with fuel for the new season is not a
practical option, transitioning from one seasonal grade to another occurs over a period of
time preceding the start of the new season. This transition requires a number of deliveries
of ‘new season’ fuel to terminals and in turn filling/service stations before the new season
begins. Achieving this transition therefore takes longer for low throughput filling stations
where deliveries occur infrequently.
The Regulations acknowledge this issue and provide a “grace period” for low volume sites
to meet new season fuel specifications. The relevant clauses in the Regulations
(footnotes 3, 4, and 9 of Schedules 1 and 2) state:
“[Fuel] that complies with the previous season’s quality and that is stored in a filling station tank to which
fewer than 3 deliveries of [fuel] have been made since 6 weeks before the beginning of the season, is
regarded as complying with this specification”
The grace period avoids fuel suppliers having to manage the seasonal transitions around
those sites with particularly low volumes, which could make the transition period longer
than would be necessary for the vast majority of sites.
The length of the grace period is not currently defined. In theory, if a fuel supplier meets
the two conditions listed in the footnote (fuel is compliant with the previous season’s fuel
specification and only two deliveries of fuel in the 6 weeks prior to the change of season)
they could supply fuel meeting the previous season specification for the duration of the
new season - as indicated by the dashed red arrow in the diagram on the following page.
6 weeks
Grace Period
Undefined
Max
Max
Min
Winter
Summer
Deliveries of fuel
Seasonal limits for specific fuel parameters
Observable quality of fuel parameter
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Whilst this is not likely to be an issue in practice, as the exemption would apply only to a
very limited number of filling stations and to take advantage of it would require a separate
fuel supply, we consider that it would be preferable if the Regulations specified the
duration of the “grace period”. The intent would be to provide for the following scenario:
6 weeks
Grace Period
28 Days
Max
Max
Min
Winter
Summer
Deliveries of fuel
Seasonal limits for specific fuel parameters
Observable quality of fuel parameter
Our initial view is that a grace period of 28 days should be sufficient for low volume sites.
Feedback is sought on this proposed period and also whether it would appropriately be
defined in terms of a number of deliveries rather than a period of time.
Q23 Would it be appropriate to define a grace period in terms of a specified
period of time, if so would 28 days be sufficient?
Q24 Would it be more appropriate to define a grace period in terms of a number
of deliveries to a filling station, if so how many deliveries?
7.4 Provisions relating to biofuels and biofuel blends
The specification for biofuels and biofuel blends were added to the Regulations in 2008
following extensive consultation. These have now been in place for two years and we are
seeking any feedback on the operation of these generally.
As with petrol and diesel the Regulations provide different specifications for fuel supplied
on a retail or non-retail basis. Specific provisions for example apply to non-retail supplies
of biodiesel/diesel.
Q25 Do you have any comments on the existing provisions relating to biofuels
and biofuel blends?
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8. Summary of Questions
Q1
Do you agree that the minimum E70 requirement in summer should be changed
from 22% to 20% for petrol?
Q2
Do you agree that the minimum MON requirement for regular grade petrol should
be reduced from 82 to 81?
Q3
Do you agree with the proposal to extend the current 7 kPa VP waiver for summer
and transition seasons to include winter?
Q4
Is any further extension of the waivers for VP, E70 and FVI necessary to facilitate
the supply of petrol/ethanol blends?
Q5
Do you agree that no further reduction in petrol sulphur is appropriate at this time?
Q6
When is it likely that 10 ppm sulphur petrol will be required by vehicles and will it
be necessary for both grades of petrol?
Q7
Do you agree with the proposal to maintain the status quo with regard to
manganese content?
Q8
Do you agree with reducing the maximum permitted inorganic chloride content
from 32 mg/litre to 10 mg/litre?
Q9
Do you agree with prescribing ASTM D 7319 and ASTM D 7328 as test methods
for inorganic chloride in place of the currently prescribed method?
Q10
Do you agree with reducing maximum diesel PAH content from 11% mass to 8%
mass?
Q11
Do you agree with the proposal to adopt ASTM D 4737, in place of ASTM D 976,
as the test method for cetane index?
Q12
Do you agree that ASTM D 4052 should be adopted as a test method for density?
Q13
Is it necessary to retain the existing method (ASTM D 1298) as a test method for
density?
Q14
Is there a need to facilitate the post-refinery blending of kerosene with diesel to
create a fuel with particularly good cold properties for our colder areas. If so in
what circumstances would it be required?
Q15
Do you agree that a density waiver for diesel/biodiesel blends up to 5% biodiesel
of 0.002 kg/m3 (giving a maximum density of 0.852 kg/m3) should be introduced?
Q16
Do you agree with reducing the limit on phosphorus for biodiesel from 10 mg/kg to
4 mg/kg?
Q17
Do you agree with adopting the test method EN 14107 for measuring phosphorus
content in biodiesel in place of the currently specified method?
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Q18
Do you agree with adopting the test method EN 15779 for measuring
polyunsaturated methyl ester content in biodiesel?
Q19
Do you agree there is a need to introduce a parameter for biodiesel relating to cold
soak filterability?
Q20
If a parameter for cold soak filterability was to be included, would the test method
ASTM D 7501-09b be suitable? If not is there any other method that would be
more suitable?
Q21
Do you have any comments on the proposal to amend the definitions of petrol and
diesel?
Q22
Do you have any comments on updating the definition of “Auckland and Northland”
to include the southern boundary of the new Auckland Council?
Q23
Would it be appropriate to define a grace period in terms of a specified period of
time, if so would 28 days be sufficient?
Q24
Would it be more appropriate to define a grace period in terms of a number of
deliveries to a filling station, if so how many deliveries?
Q25
Do you have any comments on the existing provisions relating to biofuels and
biofuel blends?
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Glossary
ASTM: ASTM International – formally the American Society for Testing and Materials.
Biodiesel: Fatty acid methyl esters.
Biofuels: Fuels derived from biomass.
BX: A blend of X% biodiesel in diesel, e.g. B5 contains 5% biodiesel and 95% diesel, B100 is pure
biodiesel.
Cold Filter Plugging Point (CFPP): An indicator of the temperature at which the precipitation of
wax crystals in distillate fuel may lead to blocking or plugging of equipment filters and fuel lines.
Cloud Point: Cloud point defines the temperature at which a clear diesel fuel becomes hazy or
cloudy due to the formation of wax crystals.
Diesel: A refined petroleum distillate having a viscosity and distillation range that is intermediate
between those of kerosene and light lubricating oil.
E70: The percentage volume evaporated at 70ºC.
Regulations: Engine Fuel Specifications Regulations 2008.
EN: European Standard.
Ethanol: Bioethanol or non-renewable ethyl alcohol which can be used as a fuel in neat form or
high level blends in specifically designed vehicles or blended at low levels with petrol for use in
vehicles with spark ignition engines.
EX: A blend of X% ethanol in petrol, e.g. E10 contains 10% ethanol and 90% petrol.
FVI: Flexible Volatility Index is a function of VP and E70. It is an indicator of hot running
performance, or the tendency for fuel to vaporise in the fuel lines when the engine is hot (known as
vapour lock) and impede fuel flow.
HSNO: Hazardous Substances and New Organisms (HSNO) Act 1996.
IP: Energy Institute, formally Institute of Petroleum.
kPa: kilopascal.
ISO: International Organisation for Standardization.
MED: Ministry of Economic Development.
MON: Motor octane number, an indicator that reflects the anti-knock performance of fuel under
high engine speed and higher load conditions.
MMT: Methylcyclopentadienyl manganese tricarbonyl, a manganese-based compound used as an
octane-enhancing fuel additive.
NZRC: New Zealand Refining Company, operates the Marsden Point Oil Refinery near Whangarei.
Petrol: A refined petroleum distillate, normally boiling within the limits of 15ºC to 220ºC.
Premium grade petrol: Means petrol supplied with a research octane number of 95 or higher.
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Regular grade petrol: Means petrol supplied with a research octane number of at least 91 but less
than 95.
RON: Research octane number, an indicator of the fuel’s anti-knock performance at lower engine
speed and typical acceleration conditions.
Vapour pressure (VP): This is a measure of the pressure exerted by the vapours delivered from a
liquid at a given temperature and pressure.
WWFC (Worldwide Fuel Charter): A set of recommendations for petrol, diesel and biofuel
specifications, produced by a group of four international automotive manufacturing associations.
The original charter was published in 1998 and has been revised a number of times since. It now
outlines comprehensive specifications for petrol, diesel, ethanol and biodiesel and is available from
http://www.acea.be/index.php/collection/fuels_guides/.
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