[pic] | COMMISSION OF THE EUROPEAN COMMUNITIES |

Brussels, 31.1.2007

SEC(2007) 55

COMMISSION STAFF WORKING DOCUMENT

Accompanying document to the Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Directive 98/70/EC as regards the specification of petrol, diesel and gas-oil that may be placed on the market and introducing a mechanism to monitor and reduce greenhouse gas emissions from the use of road transport fuels and amending Council Directive 99/32/EC to remove the elements setting the specification of fuel used by inland waterway vessels and repealing Directive 93/12/EEC Impact Assessment {COM(2007) 18 final}{SEC(2007) 56}

COMMISSION STAFF WORKING DOCUMENT

Impact Assessment of the Proposal for a Directive of the European Parliament and of the Council modifying Directive 98/70/EC relating to the quality of petrol and diesel fuels

TABLE OF CONTENTS

1. Procedural issues and consultation of interested parties 4

1.1. Organisation and timing 4

1.2. Consultation and expertise 4

2. Problem definition 7

2.1. Underlying drivers 7

2.2. Who is affected, in what ways, and to what extent? 9

2.3. How would the problem evolve, all things being equal? 10

2.4. The EU right to act 10

3. Objectives 12

3.1. General policy objectives 12

3.2. Specific/operational objectives 12

3.3. Consistency of these objectives with other EU policies and objectives, 12

4. Issues addressed in the review 17

4.1. World Wide Fuel Charter 18

4.2. Limits on FAME content in diesel 20

4.3. LPG, CNG and Biofuel specifications 22

4.4. Captive fleets 27

4.5. End date for 10ppm sulphur diesel 30

4.6. Review of Directive 99/96/EC 34

4.7. Review of CO2 and cars voluntary agreement 35

4.8. Review of Directive 1999/30/EC 37

4.9. Polycyclic Aromatic Hydrocarbons 42

4.10. Non-road mobile machinery 47

4.11. Detergent issues 61

4.12. Metallic additives 68

4.13. Diesel density 74

4.14. Oxygenate content of petrol 77

4.15. Petrol vapour pressure 92

4.16. Life cycle GHG emissions from road transport fuel 109

5. Monitoring and evaluation 118

PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES

Organisation and timing

Article 9 of Directive 98/70/EC requests the Commission to review the fuel specifications of Annexes III and IV of the Directive. The Commission has carried out an extensive review of the specifications during 2005. Based on this material and other material it is necessary to assess the need for any change to the Directive. The Commission's Work Programme for 2006 foresees a proposal to amend the Directive.

An Inter Service Group was established in April 2006 to prepare the Impact Assessment for this proposal. The Directorate Generals AGRI, ECFIN, ENTR, JRC, SG, SJ, TREN participated in the group. It held 4 meetings to prepare the draft final Impact Assessment.

Consultation and expertise

External expertise

The review of the Fuel Quality Directive covers a wide range of areas and involves a significant number of industrial sectors. Many aspects and the issues underlying them are highly technical. In view of these factors DG ENV has sought input from a wide range of bodies with relevant expertise. This input has been sought through a specific contract, a structured stakeholder process and through dialogue and meetings with individual stakeholder or groups of stakeholders.

In 2004 DG ENV entered into an administrative arrangement with the JRC to provide support for some of the technical areas in the review. JRC tackled the various areas of work with the support of different stakeholders. The work was taken forward through a number of subgroups. These dealt with detergents, metallic additives and the evaporative emissions test programme. The JRC made presentations of progress at the stakeholder meetings and responded to questions and comments. The final advice was received on 28 February 2006[1].

Consultation of stakeholders

Two stakeholder meetings were held on 5 April 2005 and 6 October 2005. All member States and a wide range of representative organisations were present at these. Organisations invited are listed in annex 1. At the first meeting there was a broad discussion of issues to be addressed in the review. At the second meeting the Commission's services presented 14 working papers focussed on the main areas of the review and setting out the main issues and possible ways forward. Stakeholders were invited to provide comments on these working papers.

To facilitate debate among stakeholders a publicly accessible CIRCA web site was established http://forum.europa.eu.int/Public/irc/env/fuel_quality/home . All presentations made at the stakeholder meetings were made available here as well as the majority of stakeholder comments. In a limited number of cases stakeholders were not willing to make their responses public.

In addition DG ENV has held meetings with ACEA, Afton Chemicals, eBIO, EBB, EFOA, EUROMOT, EUROPIA, UEPA to discuss different aspects of the review.

Respect of the Commission’s minimum standards

The Commission’s minimum standards for consultation have been met during the course of the work to review the Fuel Quality Directive. The criteria are assessed below:

Clear content of the consultation process

The objectives of the review of the Directive have been clearly described in the stakeholder meetings. The meetings have been publicised to relevant stakeholders. The Commission's services have made clear how comments received would be dealt with and how the review process would proceed.

Consultation target groups

The Directive concerns the use of Petrol and Diesel for road and non-road mobile applications. It was therefore necessary to involve in the consultation, manufacturers of equipment that would use the fuel, manufacturers of emission control equipment, fuel suppliers, suppliers of alternative fuels, environmental organisations and the Member States. These different industries were represented through EU wide organisations. Some national representative organisations requested to participate but this was rejected because it would have made the process excessively cumbersome. The Commission's services are not aware of any group that believes its views have not been represented. The publication of all the documents and most stakeholder comments on CIRCA has enabled other interested parties to follow the discussion and if they wished to submit comments.

There has not been a consultation of the general public because of the extremely technical nature of the content of the Directive.

Publication

The review of the Directive was identified within the Directive itself. Interested parties were aware that there was to be consultation on the issues to be addressed. No other publicity was required to inform the relevant stakeholders.

Time limits for participation

The Commission provided stakeholders with a month or more notice of the stakeholder meetings. For the second meeting the non-papers were circulated in the week preceding the meeting. Stakeholders have been given adequate time to provide written comments, and there have been no examples of stakeholders being unable to respond because of time constraints.

Overall, the Commission has been in ongoing dialogue with stakeholders over the course of more than a year concerning issues relating to the review. There is no reason to believe that any stakeholder believes that they have not been able to express their views.

Acknowledgement and feedback

Responses from stakeholders following the stakeholder meetings have been acknowledged and the stakeholders were asked whether their responses could be made public on the CIRCA web site.

In general the Commission has not responded to the points raised in individual responses because of the wide range of issues to be addressed and the excessive burden that this would involve. However, following the first stakeholder meeting the Commission analysed the comments received and produced a series of non-papers, which noted the range of views expressed. In some cases, meetings have taken place where the points raised by stakeholders have been further explored.

Main results and how these have been taken into account

The majority of consultation responses have been made publicly available on CIRCA. The Commission has analysed the comments. Following the first round of comments, working papers were prepared for the main subject areas that gave an indication of the range of views expressed by stakeholders. This Impact Assessment provides further indication of stakeholders views on the options.

Problem definition

Underlying drivers

Directive 98/70 established a minimum specification for petrol and diesel fuels for use in road transport. These specifications were established for health and environmental reasons. The specifications were established following the Auto Oil Programme which sought to establish the optimal balance between tighter vehicle emission standards and fuel specifications to achieve reductions of pollutant emissions for environmental and public health reasons at lowest cost.

Directive 2003/17 modified the Directive in a number of aspects. In particular it established tighter specifications for sulphur content. It also established a requirement in Article 9 of the Directive that a review should take place. This Article states:

Review process

1. By 31 December 2005 at the latest, the Commission shall review the fuel specifications of Annexes III and IV with the exception of sulphur content and propose amendments, if appropriate, in keeping with current and future requirements of Community vehicle emission and air quality legislation and related objectives. In particular, the Commission shall consider:

(a) the necessity of any change to the end date for the full introduction of diesel fuel, with a maximum sulphur content of 10 mg/kg, in order to ensure that there is no overall increase in greenhouse gas emissions. This analysis shall consider developments in refinery processing technologies, expected fuel economy improvements of vehicles and the rate at which new fuel-efficient technologies are introduced into the vehicle fleet;

(b) the implications of new Community legislation setting air quality standards for substances such as polycyclic aromatic hydrocarbons;

(c) the outcome of the review described in Article 10 of Council Directive 1999/30/EC of 22 April 1999relating to limit values for sulphur dioxide, nitrogen dioxide and oxides of nitrogen, particulate matter and lead in ambient air (*);

(d) the outcome of the review of the various commitments by the Japanese (**), Korean (***) and European (****) automobile manufacturers to reduce the fuel consumption and carbon dioxide emissions of new passenger cars in the light of the fuel quality changes introduced by this Directive and progress towards the Community target of 120 g/km CO 2 emissions for the average vehicle;

(e) the outcome of the review required by Article 7 of Directive 1999/96/EC of the European Parliament and of the Council of 13 December 1999 on the approximation of the laws of the Member States relating to measures to be taken against the emission of gaseous and particulate pollutants from compression ignition engines for use in vehicles, and the emission of gaseous pollutants from positive ignition engines fuelled with natural gas or liquefied petroleum gas for use in vehicles and amending Council Directive 88/77/EEC (*****) and the confirmation of the mandatory NOx emission standard for heavy duty engines;

(f) the effective functioning of new pollution abatement technologies and the impact of metallic additives and other relevant issues on their performance and developments affecting international fuel markets;

(g) the need to encourage the introduction of alternative fuels, including biofuels, as well as the need to introduce modifications to other parameters in the fuel specifications, both for conventional and for alternative fuels, for example the modifications to the maximum volatility limits for petrol contained in this Directive required for their application to blends of bioethanol with petrol and any subsequent necessary changes to EN 228:1999.

2. When considering its proposal for the next stage of emission standards for compression ignition engines in non-road applications, the Commission shall establish in parallel the required fuel quality. In so doing, the Commission shall take into account the importance of the emissions from this sector, the overall environmental and health benefits, the implications in the Member States regarding fuel distribution and the costs and benefits of a more restrictive sulphur level than is currently required for fuel used in compression ignition engines in non-road applications, and shall then align appropriate fuel quality requirements for non-road applications with the on-road sector by a certain date, currently expected to be 1 January 2009, to be confirmed or amended by the Commission in its review in 2005.

3. In addition to the provisions of paragraph 1 the Commission may, inter alia, bring forward:

— proposals taking into consideration the particular situation of captive fleets and the need to propose levels of specifications for the special fuels they use,

— proposals setting levels of specifications applicable to liquid petroleum gas, natural gas and biofuels.

(*) OJ L 163, 29.6.1999, p. 41; Directive as amended by Commission Decision 2001/744/EC (OJ L 278, 23.10.2001, p. 35).

(**) OJ L 100, 20.4.2000, p. 57.

(***) OJ L 100, 20.4.2000, p. 55.

(****) OJ L 40, 13.2.1999, p. 49.

(*****) OJ L 44, 16.2.2000, p. 1.’;

It can be seen that the Article lists a number of issues that should be taken account of in the review. These aspects have all been addressed by the Commission in the course of the work that has been performed. The underlying drivers of the evaluation are to determine the likely effects of changes on human health and the environment and to assess the desirability of these changes. The specific problem relating to each aspect of the review is identified in the relevant sections of the Impact Assessment.

The Thematic Strategy on Air Pollution and its related Impact Assessment carried out an in-depth assessment of the need to lower air pollutant emissions in the EU and thus improve air quality. The objective was to provide an envelope to guide future decision making. Underlying these documents was the extensive work carried out within the Clean Air For Europe (CAFE) programme to develop a better understanding of the impacts of such emissions on human health and the environment. This therefore establishes the reference framework within which measures proposed here should be assessed.

Greenhouse Gas emissions from road transport fuels account for approximately 19% of EU total emissions. So far EU measures to respond to transport Greenhouse Gas emissions have primarily focussed on reducing car emissions. Measures have also been taken to improve the attractiveness of less energy intense modes of transport. The worrying continuing increase in transport Greenhouse Gas emissions has been noted in the review of the European Climate Change Programme (ECCP), one of whose recommendations was to better monitor transport GHG emissions and to work on reducing the carbon intensity of transport energy.

The Biofuel Directive set a first step in the direction of addressing Greenhouse Gas emissions from transport fuel. The Commission is currently carrying out a review of this Directive and will consider whether it is necessary to propose any changes to the Directive. Elements of the fuel specification established in Directive 98/70 can constrain how targets for biofuel use can be achieved.

As part of the ECCP, a working group was set up to consider a comprehensive approach to reduce CO2 emissions from light-duty vehicles. The objective of this group was to assist the Commission services in preparing the review of the Community strategy to reduce CO2 emissions from light-duty vehicles, and provide assistance in the preparation of the impact assessment of the future strategy. One of the tasks of the group was to assess the potential contribution of measures that could be included in the approach taking into account their measurability, monitorability and accountability.

Who is affected, in what ways, and to what extent?

Changes in fuel specification will result in impacts on the sectors responsible for fuel supply, vehicle and equipment supply and on their users.

For the fuel supply sector, it is the parts responsible for supplying road transport fuels and fuel for non-road mobile equipment that will be most affected. Specific fuel sub-sectors can be identified that will be impacted in different ways, these are primarily: suppliers of biofuels, suppliers of fuel oxygenates, suppliers of fuel additives, oil refiners and fuel distributors.

For the manufacturing sector, it is the parts responsible for supplying road vehicles, non-road mobile equipment and engine and fuel system components that will be most affected. Specific sub-sectors can be identified that will be impacted in different ways, these are primarily: manufacturers of heavy duty and light duty vehicles, manufacturers of after-treatment equipment, manufacturers of fuel system components and manufacturers of exhaust after treatment components.

With regard to the impact of resulting changes in pollutant emissions, these will affect all citizens directly, citizens whose property is damaged by pollutant emissions, different levels of government that have responsibility for managing local air quality, and other sectors that may be affected by the need to tighten controls to achieve air quality standards. All members of the public will be affected by resulting changes in vehicle pollutant emissions. Vehicles account for a significant proportion of air pollutant emissions and the effects of this on local air quality and on human health are significant.

The impact of greenhouse gases will be felt worldwide and over a long period of time. In view of the likely changes to weather patterns, and sea levels as well as the introduction of policies to combat climate change, it is likely that the effect will be felt by all citizens and organisations. It is however difficult to predict precisely what the impacts will be.

How would the problem evolve, all things being equal?

The Thematic Strategy on Air Pollution sets out a range of air pollution objectives for Community policy to achieve by 2020. The CAFE baseline provided a thorough assessment of the level of pollutant emissions in the Community, the improvements that will be achieved through existing Community policy and the impacts of the remaining pollutant emissions on human health and the environment. The fuel used for road transport provides a major contribution to emissions of these pollutants and therefore its specification is a key element in the cost effective achievement of these objectives.

The problem will evolve differently depending on which aspect of the review is considered. Demand for petrol and diesel is projected to grow slightly[2]. The level of Greenhouse Gases emitted from the use of these fuels depends not only on their use but also on how they are produced. Without changes to the vehicle fleet and vehicle emissions standards, increased fuel consumption will, all other things being equal, result in increased pollutant emissions.

However, pollutant emissions standards for road vehicles and non-road mobile machinery are being progressively tightened. Most recently the Commission made a proposal for a Euro 5 standard for light duty vehicles. Average fleet emissions are worse than those from the most modern vehicles, but continual fleet renewal results in a gradually reducing level of overall pollutant emissions per vehicle km. To some extent this is counteracted by increasing total distances driven.

While these improvements might on one hand be claimed to reduce the need for tighter fuel standards, on the other hand certain technical improvements to vehicles (e.g. combustion and after-treatment systems) are dependent on the fuel specification.

The EU right to act

Treaty base

The EU has previously legislated in this area using Article 95. Because vehicles are primarily marketed in a single EU market, it is desirable for them to use a homogeneous fuel across the EU. Variations in the fuel specification do exist to take account of local climatic conditions, but excessive variation could lead to higher vehicle costs or malfunction. In view of the fact that the Directive, through establishing a common minimum fuel specification, creates a single market for road transport fuel, individual action by Member States in this field can no longer be appropriate.

Subsidiarity

In some areas some Member States have expressed a desire to take action that goes beyond the limits permitted by the Directive. In some cases Member States have encouraged tighter fuel specifications and implemented measures faster than required by the Directive. Some Member States have also sought to relax some requirements of the Directive. In the absence of the Directive it appears that there would be less homogeneity in the EU road transport fuel market. This would not be desirable from an environmental perspective since it would be more difficult and costly to achieve environmental performance of vehicles with differing fuels specifications. It would also be undesirable from an economic perspective since it would reduce the potential for intra-community trade in fuel and lead to higher costs for vehicle and equipment manufacturers.

Objectives

General policy objectives

The Directive ensures a single market in the fuels covered by setting the minimum specification based on environmental and health grounds. This is of particular importance to vehicle manufacturers who effectively operate on a European market.

The General Policy objectives are to ensure that environmental and health concerns arising from the use of petrol and diesel are adequately taken into account in the establishment of the minimum fuel specification. The economic costs of options need to be taken into account to ensure that the social benefits of the policy options chosen are greater than the social costs.

Specific/operational objectives

More specific objectives relate to the objectives set out in the Thematic Strategy on Air Pollution[3] which set a number of high level goals to be achieved in terms of reducing air pollutant emissions by 2020. This followed an extensive analysis of the impacts of air pollutants and set out for the Community a level of ambition in terms of reducing a range of pollutant emissions. The Thematic Strategy objectives are set at a level of ambition to achieve €42 billion health benefits per year at a cost of approximately €7 billion per year. The objectives of the strategy include reducing by 2020: SO2 emissions by 82%, NOx emissions by 60%, VOC emissions by 51% and PM2.5 by 59%. Different parameters in the fuel quality Directive impact on all 4 of these pollutants. The proposed measures need to be developed to be compatible with this objective.

Consistency of these objectives with other EU policies and objectives,

There are interactions with a number of areas of Community policy. In some cases these are over-arching strategies encompassing a wide range of policies such as the Lisbon and Sustainable Development strategies. In others these are more narrowly defined policies that have implications for a range of policy areas such as Climate Change policy. In other cases, quite a narrow objective, promoted by Community legislation has interactions with legislation on fuel quality for example the promotion of biofuels.

Over-arching strategies

Lisbon

In 2005 the Commission produced a Communication on common actions for growth and employment. This stated that the goal "is to modernize our economy in order to secure our unique social model in the face of increasingly global markets, technological change, environmental pressures, and an ageing population. This strategy is also to be seen in the wider context of the sustainable development requirement that present needs have to be met without compromising the ability of future generations to meet their own needs.

There are a number of relevant aspects to be considered. As has been noted, the fuel specification has implications for the manufacture of vehicles, non-road mobile machinery and fuel and exhaust system components. These implications can increase or reduce costs for those sectors. Similarly the specification has implications for the size of market and cost of fuel provided by fuel suppliers. It can also have implications for overall energy use.

Any measures leading to increased fuel costs will feed through into higher costs for transport and the economy. Reducing pollutant emissions will lead to lower health damage resulting in lower health care costs and a healthier population. A consistent fuel specification helps to ensure that a single market exists for road vehicles in the EU.

There are wider implications in terms of whether vehicles and machinery able to use EU specification fuel can also be sold on the world market and vice versa. These are tied in with the degree of convergence of emission specifications established for different sectors in the different major world markets.

Finally, industry needs a predictable framework to enable effective investment decisions and future research and development activity.

Sustainable Development strategy

The European Council in Gothenburg in 2001 adopted the Sustainable Development Strategy. The principles and objectives of sustainable development – economic prosperity, social equity, environment protection and international responsibilities – were reaffirmed by the European Council in June 2006 by the adoption of the renewed EU sustainable development strategy.

In the context of this review, the goal is to reduce undesirable pollutant emissions that lead to environmental and health impacts. This needs however to be done in the most economical manner and it needs to be shown that reductions are cost effective considering the societal benefit.

Climate Change

The Commission has taken many climate-related initiatives since 1991, when it issued the first Community strategy to limit carbon dioxide (CO2) emissions and improve energy efficiency. Action by both Member States and the European Community needs to be reinforced if the EU is to succeed in cutting its greenhouse gas emissions to 8% below 1990 levels by 2008-2012, as required by the Kyoto protocol.

Road transport fuel plays an important role in the production of greenhouse gas emissions. Road transport accounts for 94% of domestic EU transport Greenhouse Gas emissions, excluding international[4] transport. Transport overall accounts for 19% of EU-25 Greenhouse Gas emissions. The Greenhouse Gas emissions from the fuel per unit of energy differ depending on the fuel pathway used to produce it.

Comprehensive approach to reducing CO2 from light-duty vehicles

Within ECCP II a working group was set up on reducing CO2 emissions from light-duty vehicles. The general objective of the Working Group was to assist the Commission services in preparing the review of the Community strategy to reduce CO2 emissions from light-duty vehicles, and specifically provide a stakeholder consultation forum giving assistance in the preparation of the impact assessment of the future strategy. As regards future actions beyond the current commitments, in view of the Community’s objective of 120 g CO2/km, the Commission is preparing a Communication based upon this work.

Interactions with specific Directives

Biofuels

The Community has adopted Directive 2003/30 on the promotion of biofuels. This has as its objectives contributing to climate change commitments, environmentally friendly security of supply and promoting renewable energy sources. The Directive establishes a reference value of achieving 5.75% biofuel substitution in petrol and diesel by 2010.

The Commission adopted in 2005 a Biomass Action Plan[5] and in 2006 a subsequent Biofuel Strategy[6]. These noted the constraints on the use of certain types of biofuels established in the CEN standards for technical reasons and in the Fuel Quality Directive primarily for environmental reasons. It was noted that the Commission intended to review these limits.

As set out in these documents, for a number of reasons the desire has been expressed to further increase the use of biofuels in the Community. Beyond the current Community objective, the European Council has asked the Commission to consider the potential for reaching an 8% share of road transport fuels by 2015. These political wishes raise a number of economic, practical and environmental questions. These issues are explored in the Commission service's review of the Biofuel Directive.

The in-use environmental implications (as opposed to the impacts from their cultivation) of different biofuels vary. For example synthetic diesel generally results in much lower pollutant emissions than fossil diesel fuel and the Directive contains no constraints on its use. Synthetic diesel alone could be used to satisfy an 8% biofuel goal. The first commercial production of synthetic biodiesel, albeit produced from animal and vegetable fats, will start in 2007. With regard to petrol substitutes there are a range of options. ETBE is currently the most widely used in the EU. Ethanol may be directly blended but this gives rise to environmental problems that are explored in this Impact Assessment. Other compounds may also be used, and for example Butanol will start to be produced as a petrol substitute in the EU in 2007 and while being produced from the same feedstocks as ethanol, it avoids many of the problems associated with ethanol. Nevertheless, Butanol will not be available in substantial quantities on the biofuel market in the next years.

The existing constraints on the maximum volume of different biofuels contained in Directive 98/70 are set out below as well as the equivalent maximum energy content of road transport fuel that could be supplied if these limits were exploited to the maximum. The table is based on the ratio of petrol to diesel sales reported in 2004.

Biofuel | Constraint in Directive 98/70 | Maximum % of road transport fuel energy |

Petrol substitutes |

Ethanol | Max 5% | 1.45% | Because of the 2.7% oxygen limit, the maximum achievable is 4.4% (equal to 10% of petrol energy). |

Other alcohol | Max 10% | 3.7%1 |

Ethers | Max 15% | 3.1% 2 |

Diesel substitutes |

FAME | None3 | 56% (EN590 sets a 5% volume limit) |

Synthetic diesel | None | 56% |

1. Based on Butanol energy content

2. This is based on the Biofuel Directive definition of bio-energy content of ETBE, the energy content of other Ethers is not defined in that Directive.

3. However, a limit is currently set on FAME in EN 590 for technical reasons. CEN has been requested to review this limit and if there is no longer technical justification for it, there seems no reason why the limit would not be altered.

The Commission's biofuel strategy states that: "To capture the potential environmental benefits, a biofuel strategy has to focus on (1) optimising greenhouse gas benefits for the expenditure made, (2) avoiding environmental damage linked to the production of biofuels and their feedstocks, (3) ensuring that the use of biofuels does not give rise to environmental or technical problems." The current review of Directive 98/70 primarily concerns the third of these aspects. Biofuel technology will evolve, and this raises risks and opportunities from an environmental perspective. Because it is not possible to fully foresee the biofuel technology that will be available in 5 years time, it is desirable to foresee a further consideration of this aspect of the Directive in that time frame.

In January 2007 the Commission adopted a Biofuels progress report and Communication on "An energy policy for Europe" as part of its Energy package. In these documents it signalled its intention to achieve a minimum level of biofuel use of 10% by 2020 and a view that 14% biofuel use was achievable by that date.

Other Community legislation

There are interactions with a number of other pieces of Community legislation. Some of these are specifically referred to such as Directives 1999/96/EC[7], 1999/30/EC[8] relating to pollutant emissions while others are not such as Directive 1997/68/EC[9] on Non-Road Mobile Machinery (NRMM) emissions.

Security of Energy Supply

Transport energy plays a key role in the functioning of the EU economy. The security with which this can be supplied is therefore important and has been discussed by the Commission in a Green Paper[10]. The concept of security of supply encompasses a wide range of different issues and many factors impinge on the overall level of supply security.

A uniform fuel standard across the EU improves the fungibility of the fuel system and its robustness to disruption. The extent to which EU consumption is supplied from EU production has an impact on the likelihood of supply disruption for political purposes. However, the degree to which any one producer can disrupt fuel supply is in itself dependent on that producer having a degree of control over the market. Some sources of supply may be more vulnerable to disruption than others, for example because of geopolitical factors, for technical reasons or if they are dependent on weather conditions.

In the Commission's Biofuels Progress Report adopted on 10 January 2007it stated that:

"-Biofuels contribute to short-term security of energy supply by reducing the need to keep oil stocks to protect against disruptions. The value of this can be estimated at about €1 bn per year (under the hypothesis of a 14% biofuel share).

- The best way to promote long-term security of supply is to diversify energy sources. In transport, energy diversity is rather low. Biofuels add to energy diversity by increasing the diversity of fuel types and of regions of origin of fuels. It is not obvious how to place a monetary value on this benefit."

It is clearly desirable that changes to Directive 98/70 should not exacerbate risks to the security of energy supply in the EU. The potential implications of modifications to security of energy supply are discussed where appropriate in the individual sections of the Impact Assessment.

Issues addressed in the review

Directive 98/70 establishes limits on 23 parameters of petrol and diesel. Article 9 of the Directive contains 10 paragraphs specifying areas for consideration within the process of the review of the Directive. Many of these areas cover a range of possible parameters. It has been necessary to limit the scope of the review to areas that it is most useful and appropriate to address.

During the stakeholder process and building on the areas requested for consideration in the Directive, the following main areas have been identified for investigation.

1. World Wide Fuel Charter

2. Biodiesel limits in diesel

3. LPG, CNG and Biofuel specifications

4. Captive fleets

5. End date for sulphur in diesel

6. Review of Directive 99/96

7. Review of CO2 and cars

8. Review of Directive 99/30

9. Polycyclic Aromatic Hydrocarbons

10. Non-road applications

11. Detergents

12. Metallic additives

13. Diesel density

14. Petrol ethanol ETBE and oxygenate content

15. Petrol vapour pressure

16. Lifecycle Greenhouse Gas emissions

For each of these areas an assessment is provided of the policy options in the following sub-sections.

World Wide Fuel Charter

The problem

The World Wide Fuel Charter (WWFC) is a proposal from car manufacturers recommending harmonisation of fuel standards. Adoption of such harmonised standards would facilitate the marketing of vehicles calibrated for many different markets. In establishing the proposed fuel specifications in the charter, it seems unlikely that car manufacturers will have taken full account of the implications for other sectors such as fuel suppliers.

Policy options

The review currently being performed of Directive 98/70 considers a number of different fuel characteristics. Possible changes to these characteristics are assessed for their effects and a conclusion reached based on this analysis. In asking for the WWFC to be adopted, the automotive industry is asking, rather than for such a parameter by parameter analysis, for the existing fuel specification to be replaced by that within the WWFC. Therefore the options are either:

- Do nothing

- Adopt the WWFC specifications in place of the existing fuel specifications in the annexes.

Impact of the options

The do nothing option, implies that those aspects of the fuel specification that have been proposed in the stakeholder discussions or in the Directive to be considered for review will analysed one by one and a conclusion reached on the desirability of change. Changes would therefore be made only if these made sense through taking account of their impacts on all the relevant sectors and parameters.

The option of deciding whether or not to adopt the WWFC specifications implies making a decision on the totality of the specification. This could be done through an extensive analysis of the difference between the WWFC specification and the existing EU specification and summing together the impacts.

Comparing the options

After the automotive industry requested consideration of the use of the WWFC specification, the Commission asked it to bring forward evidence showing that modification of the parameters requested would result in improved environmental performance that can be justified from a cost-benefit analysis point of view. The WWFC is supported with data suggesting that the proposed changes would provide environmental benefit. However, the conclusions to be drawn from this data are disputed and different trends or different conclusions are put forward by other stakeholders. In some other cases, while there is evidence that by modifying certain fuel parameters, e.g. cetane number, emissions can be reduced, it has not been demonstrated that this is justified in cost-benefit terms.

It should be recalled that the oil companies' European Association for environment, health and safety in refining and distribution (CONCAWE) published a paper[11] in 1999 assessing the proposed WWFC standards. This paper stated that while fuel quality changes alone have a relatively small impact on emissions from engines of a given technology, they offer great potential to reduce emissions if used to enable new engine technologies.

The evidence requested has not been offered and therefore the request for wholesale adoption of the WWFC specification was not further considered. Nevertheless, many of the specific aspects addressed in the WWFC are extensively analysed elsewhere in this Impact Assessment.

Preferred Option

The preferred option is to assess the impacts of changing those individual fuel characteristics where a need has been identified.

Limits on FAME content in diesel

The problem

The diesel specification contained in the Directive does not specify a maximum limit for FAME content. Such a limit is established in European Standard EN 590 for technical reasons, because of a number of technical concerns principally over the stability of FAME and its effect on injection equipment..

During the stakeholder process, the FAME industry requested that consideration be given to putting in place a limit setting a maximum FAME content for diesel in Directive 98/70. No evidence has been provided by any stakeholder of any justification for the establishment of such a limit on health or environmental grounds. However, the fuel injection equipment manufacturers have reiterated their concerns over higher proportions of FAME than permitted in EN 590. The Commission is not in a position to assess the accuracy of these claims.

Policy options

The options available are to:

- Do nothing,

- Consider establishing a limit on FAME in Directive 98/70

- Request CEN to reconsider the evidence and determine whether the existing FAME limit in EN 590 is justified.

Impact of the options

The do nothing option would leave the existing EN 590 limit in place. Current EU levels of FAME use are significantly below the maximum permitted in EN 590 and so this does not constrain the current use of FAME in the EU. However, investment in FAME may be constrained because of the current future prospects for development of the EU market for FAME. The development of more advanced bio based diesel substitutes is likely to lead to a situation where, because of their better fuel characteristics, and ultimately the introduction of more advanced biodiesel production technologies with better greenhouse gas balance, the CEN limit on FAME will cease to be important.

A limit for biodiesel could be established in Directive 98/70. There do not appear to be convincing reasons for health or environmental reasons to establish such a limit, and therefore it would not be expected that any health or environmental benefit would flow from it. The existing limit is established for technical reasons and these appear to provide the major justification for establishing a limit on FAME. The Commission's Better Regulation initiative aims to make sure that regulation is used only when necessary. In this case, there is no convincing reason to duplicate the CEN limit in Community legislation.

A request could be made to CEN to reconsider the evidence in the light of subsequent technical progress and determine whether or not the limit in EN 590 remains justified or not. This would have the benefit that the relevant industry experts would be brought together to reappraise the evidence.

Comparing the options

Since the limit in EN 590 is established because of technical concerns principally over the stability of FAME and its effect on injection equipment, , were the Commission to consider overturning this limit it would need to consider whether the technical reasons for the limit were invalid or had been superseded. This is beyond the scope of the current review and is a process that should more appropriately be considered within the appropriate technical body. Liability issues might arise were a decision taken to overrule the existing technical limit if this was then discovered to cause malfunction or damage to vehicles.

The absence of evidence of any significant environment or health problems arising from the use of different proportions of FAME has led to no further consideration being given to introducing a maximum limit for FAME content in diesel.

The Commission has already requested CEN to reconsider the limit set in standard EN 590. This clearly rules out further consideration of the "no action" option and in view of the difficulties inherent in the other option appears to be the optimal way forward.

Preferred Option

The Commission has requested CEN to reconsider the FAME limit set in EN590. Because there are no good reasons for a limit on FAME content in diesel to be set in Directive 98/70 no other action is proposed.

LPG, CNG and Biofuel specifications

The problem

There might be a need on the grounds of environmental or health protection to establish specifications for one or more of these fuels as has been done for petrol and diesel. In recognition of this, Article 9, paragraph 3 of Directive 98/70 states that the “ Commission may bring forward proposals setting levels of specifications applicable to liquid petroleum gas, natural gas and biofuels. ”

There may also be technical reasons for defining EU wide specifications for these fuels. For example, to facilitate their use across the single market. This has been suggested in the case of natural gas. Nevertheless, the establishment of specifications for fuels based purely on technical reasons falls outside the scope of the Directive. In view of this, it is also necessary to consider whether the scope of the Directive should be expanded to include technical reasons.

The Directive specifications only cover fuels that are at least 70% derived from mineral oil. There may therefore also be a need to consider whether fuels that contain less than 70% mineral oil might be put on the market and raise health or environmental risks.

Whether specific vehicle emission standards are required for these different fuels is not considered.

CEN standards

CEN standards exist for Fatty Acid Methyl Esters (FAME) (EN 14124?) for automotive use, and automotive LPG (EN 589). CEN/TC 19 is working on an ethanol standard for blending up to 5% in petrol. A workshop agreement has been concluded on emulsion fuel (CWA 15145:2004). Development is also currently underway on a workshop agreement concerning ethanol fuel (E85) for use in flexible fuel vehicles (FFV).

A CEN working group (CEN/BT/WG 149) has reported on “The need for European Standards for liquid and gaseous alternative fuels” on 6th December 2004. This recommended some further action in a number of fields.

Other alternative fuels

It is also worth considering other potential transport fuels and therefore DME, Hydrogen, emulsion fuel and synthetic fuels are also covered.

There have not been any requests by stakeholders on environmental or health grounds to set specifications for LPG, CNG, hydrogen, emulsion fuel or synthetic fuels.

It has previously been suggested by the European Natural Gas Vehicles Association (ENGVA) in the Commission Alternative Fuels Contact Group, established to consider economic and technical barriers to CNG playing a larger role as a transport fuel, that it could be desirable to establish minimum specifications for transport fuel CNG. It was suggested that these specifications could relate to oil, moisture and impurity content.

Policy options

The options available are:

- No action

- Set specifications for one or more of these fuels.

- Extension of the scope of the Directive to regulate fuel specifications for technical reasons.

Impact of the options

In discussing the impact of the options in this section, climate change impacts are not addressed. This is because in general, the climate change impacts of different fuels are highly dependent on the pathway employed for the production of the fuel. The degree of dependence varies between fuels, being highest for hydrogen, fairly high for biofuels and less dependent for LPG and CNG. Climate change issues relating to different fuel pathways are addressed in section 4.16.

LPG and CNG

An argument frequently advanced for greater use of LPG and CNG as road transport fuels in the past is that these are cleaner burning fuels than petrol or diesel resulting in lower levels of pollutant emissions and less health damage. The reasons for this relate firstly to their relatively homogenous hydrocarbon composition, and the fact that because they are gases, there are no issues relating to vapourisation resulting in more complete combustion. These factors mean that there is likely to be a need for less stringent after-treatment equipment to achieve emission standards. As vehicle emission standards are increasingly tightened for petrol and diesel vehicles, it is likely that the pollutant emission benefit of these fuels will disappear.

There do not appear to be any environmental benefits from including specifications for LPG and CNG in the Directive. For CNG, it has been noted that there could be benefit to the wider use of CNG as a transport fuel if a uniform specification was agreed. With regard to LPG, the existence of a CEN standard indicates that there would be no economic or social benefit from including a specification in the Directive. Nevertheless, the Commission's attention has been drawn to the fact that there may be technical problems arising from the technical requirements currently set by EN589. In view of this, the Commission proposes to approach CEN to consider whether there is a need for modification or clarification of the standard.

Biofuels

With regard to biofuels the situation is rather more complex. The term biofuel covers a large range of potential fuels. At present the main biofuels used in the EU are ethanol (used as ETBE) and FAME. The potential impacts of ethanol as a blend in petrol are discussed in section 4.14.

Synthetic fuels may be produced from different feedstocks such as coal, gas and biomass, but the resulting products are very pure paraffinic hydrocarbons that are indistinguishable. Information provided by industry shows that these fuels produce substantially less pollutant emissions than conventional diesel and there are no additional known health impacts beyond those from conventional diesel engine emissions.

The only aspect considered here is whether a full specification for any or all biofuels needs to be contained within this Directive. The effect of neat ethanol and biodiesel on pollutant emissions appears to be unclear. Study results are inconclusive particularly for certain pollutants. A key factor is that neat ethanol and biodiesel have very different properties compared to conventional diesel and petrol. For example, biodiesel has a much higher density, a narrower distillation curve and a higher average boiling point than diesel fuel. In general engine parameters are optimised for conventional fuels and therefore neat biofuels can lead to non-optimal functioning of the engine with worsened environmental performance. However, this situation might change if engines and their management systems were optimised to use high biofuel blends of fuel. While this might point to the desirability of regulating these fuels, there is no evidence that there is a problem with the composition of the fuel or the existence of impurities or other compounds. If this is not the case then it is difficult to see what gain for health or the environment would be achieved through such a regulation, however it does point to the need to control the mixture of these fuels with conventional fuel and the need to ensure that fuel specification remains as homogenous as possible.

If no action is taken in the Directive, it does not preclude other action such as further standardisation work by CEN in relation to these fuels

DME and Hydrogen

In the case of DME and Hydrogen, which are both gases at room temperature and pressure, it is likely that these will also be supplied in a very pure form as a result of the production processes employed. There do not seem to be particular risks from pollutant emissions with using these fuels, although results are not conclusive for DME, nor the need to manage trade offs between fuel suppliers and vehicle manufacturers to achieve desired levels of exhaust cleanliness. At the extreme where hydrogen is used in fuel cells, the only emission is water vapour. With regard to the purity of hydrogen, it should be noted that there is a trade-off between the cost of purifying the gas and the cost of the fuel cells. This may indicate the desirability of establishing purity levels in the future.

Emulsion Fuels

Emulsion fuels are produced through emulsifying a blend of water and diesel with the use of a surfactant to ensure that the emulsion remains stable. These fuels are reported to consistently result in significant reductions in PM, NOx and CO emissions. An extensive study performed by CARB[12] and confirmed by others has shown that emulsion fuels can results in an increase of some pollutants, especially unburnt hydrocarbons; however CARB concluded that the benefits to PM emissions are overwhelming compared to the possible adverse effects on some other emissions. The existence of a CEN workshop agreement for emulsion fuels indicates that there would be no economic or social benefit from including a specification in the Directive.

Other impacts

Any change to the coverage of fuels by the Directive would impact primarily on suppliers of that fuel who would then have to ensure compliance with the relevant specification. There is unlikely to be any significant impact on the general public because no significant health or environment risks have been identified. There could be some impact on vehicle manufacturers and fuel retailers who might benefit from handling a more homogeneous fuel. Nevertheless, as noted, the existence of a number of CEN agreements in this area limits this potential impact.

It is not considered likely that the situation in relation to the fuels discussed will change. The fuels themselves are unlikely to become more contaminating and it is not considered likely that any major new health or environmental risks will be identified.

Comparing the options

There does not appear to be any demand for addressing CNG, LPG or biofuel specifications in Directive 98/70. Where a CEN standard already exists, there is unlikely to be a single market benefit from introducing such a specification in Directive 98/70.

DME and Hydrogen are fuels that are not yet commercialised. There is no evidence that a lack of an EU specification is hampering their introduction although the need for such a specification may well arise. In view of the lack of identifiable health and environmental risks presented by these fuels addressing this through Directive 98/70 is probably not the most desirable approach.

It has been noted that CEN has undertaken work on technical standards for biofuels, LPG and emulsion fuel. In view of its expertise, this would probably the most appropriate sphere for defining any further technical specification for the fuels discussed.

Ranking the options

For the different fuels considered, an assessment of the likely change from setting further EU specifications is set out below.

LPG | DME | CNG | Hydrogen | Biofuel | Emulsion Fuel |

Health and Environmental benefits from establishing specification in 98/70 | No – generally lower pollutant emissions than conventional fuel | No – generally lower pollutant emissions than conventional fuel | No – generally lower pollutant emissions than conventional fuel | No – lower pollutant emissions than conventional fuel | Reported impacts vary. Some pollutant emissions appear lower. | No– lower pollutant emissions than conventional fuel |

Single market benefits from establishing specification in 98/70 | No (CEN standard) | No – no market at present. | Possibly | No – no market at present. | No - (CEN standard for FAME and E85 workshop agreement) | No - (CEN workshop agreement) |

Benefit from establishing a technical specification | No | Possibly | Possibly | Probably | Possibly in some areas | No |

Since pollutant emissions are generally lower from combustion of the fuels considered than for conventional petrol or diesel, there is not a strong case for regulating their specification through Directive 98/70. In addition, the market share of these various fuels is currently small, and even in the most optimistic scenarios will only supply a small proportion of the market in the foreseeable future. These factors combined indicate that only a very limited health and environment benefit, if any, could be derived from regulating the specification of these fuels in the Directive. If such a regulation were to add cost to the fuels it could even have an adverse effect through discouraging their take up. Where there is no European standard, single market benefits could be realised, however this may be most appropriately pursued through standardisation.

Preferred Option

In view of the expertise of CEN in establishing technical standards for fuels, and the absence of any request from stakeholders that this task should be included in the scope of the Directive, it is concluded that the scope of the Directive should not be extended to cover technical questions relating to fuel specification in line with the Commission's better regulation initiative.

In view of the lack of health and environment benefit and the undesirability of extending the scope of the Directive to cover technical issues, specifications for the fuels considered should not be included in Directive 98/70.

Captive fleets

The problem

There might be environmental or health benefit that could be realised by establishing special specifications for fuels used by captive fleets. This could arise because of their use in urban areas where there might be specific air quality problems.

Only one stakeholder commented specifically on this aspect of the review suggesting that it might be desirable to establish special fuels for captive fleets but did not provide any further detail on the desirability of addressing any particular parameters of the fuel specification or the cost or practicality of doing so.

Policy options

The options available are:

- No action

- The definition of a specific captive fleet fuel in the specification.

The no action option would retain the existing rules in the Directive. Article 6 of Directive 98/70 states that “ By way of derogation from Articles 3, 4 and 5 and in accordance with Article 95(10) of the Treaty, a Member State may take measures to require that in specific areas, within its territory, fuels may be marketed only if they comply with more stringent environmental specifications than those provided for in this Directive for all or part of the vehicle fleet with a view to protecting the health of the population in a specific agglomeration or the environment in a specific ecologically or environmentally sensitive area in that Member State, if atmospheric or ground water pollution constitutes, or may reasonably be expected to constitute, a serious and recurrent problem for human health or the environment ”. It may be concluded that it is therefore possible for a Member State to establish specific criteria, for example for captive fleets, in a given area provided that there are specific health or environmental justifications.

Analysis of impacts

There are two reasons indicated why it may be desirable to establish specific fuel specifications for captive fleets.

In the first case this is because captive fleets may offer a means of introducing new or alternative types of fuels into a self contained market. Captive fleets can facilitate the use of unconventional fuels such as LPG, CNG, DME, hydrogen, high blend biofuels and emulsion fuels. This avoids the problem of introducing the fuel at a sufficiently wide proportion of filling stations for it to be useable by vehicles operating freely throughout the territory. The possibility of establishing specifications for these fuels is discussed in section 4.3. With the exception of emulsion fuels, all of these fuels require specially purchased or adapted vehicles. A decision to acquire such vehicles would necessarily involve making arrangements for the supply of the fuel required. These factors mean that no further consideration needs to be given to this aspect here.

The second case may arise because of air quality problems in a specific area, almost certainly urban. The question to be answered is whether there is benefit in air quality terms to be derived from defining a specific alternative specification for petrol and diesel compared to that for general use. If there is such benefit, does the Directive need to be modified to achieve this and would the benefits outweigh the costs.

It is unlikely that specially adapted vehicles would be manufactured for this segment of the market and therefore that the environmental benefit would need to be achievable from the use of the fuel in conventional vehicles. This issue is considered in general within the review for a number of elements of the petrol and diesel specification to assess whether there would be environmental benefit from a further tightening of the general specification.

For those aspects of the specification where it is concluded that it is not desirable to change the general specification, this indicates that if the situation is different for a specific geographic area it must be because the nature of that area is such as to give rise to very different costs for example for abatement of pollutant emissions from other sources. This would indicate that the problem to be tackled must be highly specific to that narrow area. This argues against the possibility of defining a single “captive fleet” blend since the problems to be addressed may differ throughout the Community. Many such specific problems can also be tackled in other ways.

It is likely that the use of such a specialised fuel in such a limited way would pose economic challenges. The Commission does not believe that a generalised need for a specialised fuel specification for captive fleets have been demonstrated.

Comparing the options

No action | Captive fleet specification |

Availability of special fuel for urban captive fleets | Possible provided Article 6 is complied with. | Possible |

Ability to reduce PM | Further fuel possibilities already exist eg non-sulphur diesel and emulsion fuels. Low Emission Zones may also be employed. Filters may also be employed. | In addition to the no-action options, the captive fleet specification, if it offered lower PM emissions, would provide a possible means of reducing PM. |

Ability to reduce NOx | Emulsion fuels may be used to reduce NOx emissions. NOx traps may also be employed. | In addition to the no-action options, the captive fleet specification, if it offered lower NOx emissions, would provide a possible means of reducing NOx. |

Air quality | In addition to the possible specific measures on fuels and vehicles listed above, air quality can also be improved by restrictions on more polluting vehicles and traffic restrictions. More cost effective non traffic related options may exist. | In addition to the no-action options, the captive fleet specification offering lower emissions would provide a possible means of improving air quality. The effect of the captive fleet fuel would depend on the proportion of total emissions produced by the captive fleet, which is likely to be small. |

Vehicles | No change | Unlikely that vehicles will be developed specifically to use “captive fleet” fuel. No evidence has been presented of any vehicle technology that would be introduced in captive fleets if a different fuel specification were available. |

Refiners | Logistic challenges could arise if special fuel is required under Article 6, the cost of which would be passed on to the user. | Logistic challenges could arise if special fuel is required, the cost of which would be passed on to the user. |

Local authorities | Options other than fuel exist to tackle specific local air quality problems. If a need is identified for special fuel, this can be required under the procedure in Article 6. Local Authorities would need to establish the cost effectiveness of this compared with other measures. | Options other than fuel exist to tackle specific local air quality problems. Captive fleet specification fuel would be available as an option. Local Authorities would need to establish the cost effectiveness of this compared with other measures. |

Preferred Option

Many options are available for addressing air quality problems, and in particular transport sources of emissions. The option of establishing a captive fleet fuel specification offers little if any environmental benefit over other alternative approaches. The specific nature of the local air quality concerns mean that it is not possible to establish at an EU level what the most economically desirable approach would be to address such local problems.

The current possibility provided by the Directive does enable a tighter fuel specification to be employed if this is considered to offer the most attractive ratio of costs to benefits. No overall EU benefit has been identified from establishing a specific captive fleet specification. In view of this and the absence of any specific request for a tighter specification of fuel parameters for captive fleets, no action is the preferred option.

End date for 10ppm sulphur diesel

The problem

10ppm sulphur diesel is an enabling fuel for higher vehicle efficiency due to the fact that its use results in the need for less regeneration of DPFs. Reducing sulphur content also leads to benefit in SO2 and PM emissions. Sulphur content is also relevant to the future introduction of De-NOx after-treatment systems since it can poison these.

Article 4(1)e of Directive 98/70 establishes a maximum sulphur content of road diesel of 10ppm to take effect provisionally from 1 January 2009. However this end date is subject to the provisions of Article 9(1)(a) which requires the Commission to consider “the necessity of any change to the end date for the full introduction of diesel fuel, with a maximum sulphur content of 10 mg/kg, in order to ensure that there is no overall increase in greenhouse gas emissions. This analysis shall consider developments in refinery processing technologies, expected fuel economy improvements of vehicles and the rate at which new fuel-efficient technologies are introduced into the vehicle fleet”.

The Directive's provisional end date may be confirmed or modified on the basis of an assessment of the various contributory factors.

Policy options

The Directive contains a provisional end date for 10ppm sulphur. It is necessary to confirm or modify this date and therefore no action is not an option.

The options available are:

- To confirm this current end date of 1 January 2009

- To propose an alternative date. This date could be earlier or later.

An earlier date has been requested by some stakeholders, however this option was quickly discarded because it will in practice not be possible for the proposal to complete its legislative process in the European Institutions and be transposed into national law in time to allow an earlier date.

Analysis of Impacts

The main implications of the change in diesel sulphur content relate to lower emissions of SO2 and PM from all diesel engined road vehicles and higher CO2 emissions from oil refineries. Because refineries are included in the Emission Trading Scheme, the increased CO2 emissions will mean that a larger number of allowances will be required implying additional cost. The investment and allowance costs are likely to lead to a small increase in fuel costs which will be passed on to final consumers.

The main stakeholders that will be affected by this decision are oil refiners and fuel suppliers. Automotive manufacturers will also be affected in view of the impact of the fuel specification on the technical characteristics of the vehicles and their ability to conform with vehicle emission standards and the voluntary agreement.

Most stakeholders were supportive of confirming the end date for 1/1/2009 or of advancing the date, particularly if this would result in environmental benefits. A number suggested that an earlier end date is feasible. It was suggested that the earlier introduction has other benefits in particular enabling the use of NOx reduction technologies.

CONCAWE has recently published[13] an update of its modelling of the cost and CO2 implications of 10ppm sulphur. This concludes that the cost and CO2 emissions for moving from 50ppm to 10ppm diesel are approximately half of those estimated in 2000. The figures are now €3.2 billion and 1.1-1.4Mt CO2 per year.

To provide technical background for the decision, the JRC carried out an analysis of the factors influencing the desirable end date for 10ppm sulphur in diesel. The main conclusions from this work are:

- CO2 break-even only occurs if a sufficient number of vehicles present a sufficient energy benefit from 10ppm sulphur diesel. However, the break-even date is highly sensitive to the assumed energy benefit. Changing this from 2% to 1% moves the date from around 2010 to around 2015.

- It is very difficult to precisely foresee developments because of e.g. EURO 5 levels, fleet renewal, territorial disparities, DPF technology and regeneration strategies, impact of heavy and medium duty vehicles, impact of “real world” driving.

- Modelling already shows that the cost and GHG emissions from the refining side are lower than first thought. Continuous enhancement of refinery processes reducing the additional GHG due to 10ppm sulphur diesel production could be expected.

- Confirmation of the 2009 end date taking into account only GHG/energy aspects is not clearly demonstrable, as the GHG break-even parameter is unclear and uncertain.

- 10ppm sulphur diesel also has benefits for regulated pollutant and emission abatement.

- Low sulphur fuels are beneficial for PM reduction from pre 2005 vehicles. The fuel is also considered vital for advanced combustion engine concepts. For advanced engines with PM traps, the impact on PM reduction is much less apparent.

- By reducing regeneration frequency for PM traps and NOx storage traps, there may be an impact on vehicle fuel economy.

One important factor not considered in JRC’s modelling of impacts is the medium and heavy-duty fleet, which uses 70% of road diesel. New technologies with a potential efficiency gain are only expected after 2008. In view of the rate of fleet renewal, and the lack of data on these technologies at present, the impact of this class of vehicle was not included. However, even a small effect would be significant.

With regard to the security of supply of diesel fuel, requiring 10ppm sulphur diesel could limit the range of suppliers of diesel fuel to the EU. At present the EU imports significant volumes of diesel. Refiners of this fuel will need to carry out the necessary upgrading and investment if they wish to carry on supplying diesel to the EU. There is no reason to believe that this investment will not be possible since the EU market for diesel is predicted to remain buoyant.

In their responses to the Euro 5 consultation stakeholders have stated the need to have 10ppm diesel fuel available for the technologies that will be required. While the date of coming into force of the new standard is not known, the possibility that this could be some time in 2009 is not unlikely.

To some degree there may be a chicken and egg situation, in that vehicle manufacturers will be reluctant to deploy technologies that need 10ppm sulphur diesel or that may be damaged by higher sulphur levels if it is not certain that this fuel will be widely available. Certainty about the end date will then enable manufacturers to make their plans for the roll out of technology appropriately.

Fuel quality monitoring shows that there has been a gradual roll out of 10ppm sulphur diesel across the EU. Monitoring data for 2004 shows that 10ppm sulphur fuel accounted for around 25% of all EU diesel sales.

Basing a decision on the 10ppm sulphur end date purely on the impact on CO2 emissions is difficult in view of the uncertainties identified. Other environmental benefits flow from 10ppm sulphur diesel and these will be achieved regardless of the outturn of the other uncertain factors. In addition, the achieving of Euro 5 emission standards appears to be dependent on complete availability of 10ppm diesel. Since achieving the 2009 end date does not appear to present any major difficulties and will deliver environmental benefits it seems desirable to confirm this date.

Comparing the options

The positive and negative aspects of the options to confirm the 2009 end date and to set a later end date are set out in the table below with reference to the different stakeholders. This assessment does not consider what the later end date would be. If this latter option were favoured then a balance of the different impacts would need to be made to establish the optimal date.

Confirm 2009 | Set later date |

Refiners | Provides certainty, in particular for investments. Fits with expectations. | Uncertainty unless a new date is fixed. New date cannot be fixed with any greater certainty than the 2009 date. |

Vehicle manufacturers | Helps with vehicle emission control, eg enabling Euro 5 technologies. Will enable higher efficiency vehicles, eg through reducing trap regeneration frequency. | Greater uncertainty and difficulty for vehicle manufacturers in meeting tighter vehicle emission standards |

Air Quality | Will result in lower PM emissions from all diesel vehicles. Greater benefit will flow from older vehicles so the greatest benefit will be early. Through enabling Euro 5 it facilitates the next stage in vehicle emission reductions. | Lower PM emissions from all diesel vehicles will be delayed. As older vehicles are retired from the fleet the possibility of PM reductions from their emissions will be lost. |

Greenhouse gases | Possible small overall increase in GHG emissions. However, this might be offset by improved HDV efficiency. | Might result in slightly lower emissions over the time period considered. However it might delay introduction of more efficient vehicle technology, thus hampering CO2 and cars strategy and leading to higher emissions overall. |

Economics | Costs are estimated to be substantially lower than originally calculated. Now around €3.2 billion | Costs unlikely to differ substantially from an end date of 2009. Technical advance could lead to cost reductions. |

Local Authorities | Assists Local Authorities to meet 2010 PM targets by reducing transport PM emissions. Facilitates use of NOx traps on vehicles after phase in. | Will not assist meeting of 2010 PM targets. Will delay possible introduction of NOx traps till after the new later date. |

Preferred Option

Article 9(1)(a) requests that the decision on the end date should be based on ensuring that there is no overall increase in GHG emissions. As described, this cannot be established with certainty. The analysis based on light duty vehicles indicates that the break even point for GHG emissions might be later than 2009. However, this does not take account of any possible energy saving from Heavy Duty Vehicles. Even if there was a small benefit for HDVs, in view of their large share of the fuel used, this could have a significant impact on the aggregate GHG emissions.

However, it is equally the case that there are no clear benefits in any of the areas considered from delaying the end date of 10ppm sulphur diesel beyond 2009. The only possible benefit is that there might be a slight GHG saving from doing so, but as noted this is uncertain.

A confirmation of the 2009 end date will deliver immediate air quality benefits from all diesel road vehicles and provide assurance to vehicle manufacturers about the future fuel that will be provided to vehicles, thus enabling them to roll out new technologies requiring it. Complete coverage of 10ppm diesel also facilitates the achievement of the Euro 5 emission limits. Although it is not possible to base a definitive conclusion on the greenhouse gas emissions alone, in view of these other identifiable benefits and the substantial progress that has been made so far, it appears desirable to conclude that the end date for 10ppm sulphur in diesel should be confirmed as 1 January 2009.

Review of Directive 99/96

The problem

Directive 1999/96/EC amending Directive 88/77/EEC established emission limits for Heavy Duty Vehicles (Euro IV from 1 October 2005 and Euro V from 1 October 2008). This Directive has been recast as Directive 2005/55/EC and Commission Directive 2005/78.

Directive 98/70 requested that the Commission consider “ the outcome of the review required by Article 7 of Directive 1999/96/EC on the approximation of the laws of the Member States relating to measures to be taken against the emission of gaseous and particulate pollutants from compression ignition engines for use in vehicles, and the emission of gaseous pollutants from positive ignition engines fuelled with natural gas or liquefied petroleum gas for use in vehicles and amending Council Directive 88/77/EEC and the confirmation of the mandatory NOx emission standard for heavy duty engines ”.

Directive 98/70 does not contain specifications for natural gas or LPG. The possibility of establishing specifications for these fuels is discussed in section 4.3.

The review required by Art.7 of Directive 1999/96/EC has been carried out in connection with the recasting of Directive 88/77/EEC.Following this the Commission is currently working on the preparation of a further Euro VI stage for HDV emissions that will further tighten the limit values.

Stakeholders have been asked in advance of the preparation of the Euro VI proposal by the Commission, by means of a questionnaire what fuel quality would be required for different limit value scenarios. A draft summary of the responses is available. No proposal for a Euro VI standard has yet been agreed and therefore the precise requirement for the fuel cannot yet be inferred. Nevertheless, there are indications that fuel composition will not need to be altered to comply with any likely change in emission requirements for HDVs.

During the course of the discussions with stakeholders for the review of the Fuel Quality Directive, none have expressed any views on fuel quality in relation to further tightening of HDV emission standards.

Policy options

No action appears to be the only option.

Preferred option

There should be no change to the diesel specification in response to the review of HDV emission limits.

Review of CO 2 and cars voluntary agreement

The problem

There might be a need to make amendments to the fuel specifications in Directive 98/70, other than the sulphur content of diesel, in view of the need to facilitate further reduction in CO2 emissions from passenger cars in line with the voluntary agreements with the car manufacturers. In view of this the Commission is requested to consider “the outcome of the review of the various commitments by the Japanese (JAMA), Korean (KAMA) and European (ACEA) automobile manufacturers to reduce the fuel consumption and carbon dioxide emissions of new passenger cars in the light of the fuel quality changes introduced by this Directive and progress towards the Community target of 120 g/km CO 2 emissions for the average vehicle ”.

Stakeholders have not expressly requested any modification to the fuel specification in relation to the current CO2 and cars voluntary commitments. In particular, ACEA and JAMA carried out jointly with the European Commission as part of the monitoring of their commitments a review[14] of the situation up to 2003 included. Both associations expressed general satisfaction with the fuel qualities provided during the review period. KAMA carried out the same review exercise covering the commitment period up to 2004, and signalled a general satisfaction similar to the other two associations.

The review of the Community strategy on CO2 and cars to move beyond the current commitments towards the Community objective of 120 g CO2/km has been completed and the Commission has published a Communication. There is no indication from the analysis that has been carried out that fuel specification changes are required to enable further progress in improving the efficiency of light duty vehicles.

Policy options

No action appears to be the only option to be considered.

Analysis of impacts

It is conceivable that certain engine designs might require a tighter or different specification fuel for optimal operation. There could be an interest in introducing a new engine design to achieve a higher combustion efficiency, for example the introduction of 10ppm sulphur petrol was driven by the desirability of introducing more efficient direct injection petrol engines.

As noted there have been no specific requests for fuel specification changes related to CO2 emissions or engine efficiency in either the process of reviewing the voluntary agreements or reviewing Directive 98/70. However, it cannot be ruled out that ongoing research could in the future identify new fuel requirements, for example in relation to HCCI technology.

Preferred option

With the exception of diesel sulphur content discussed in section 4.5, the fuel specifications do not need to be adjusted to enable vehicle manufacturers’ compliance with the current voluntary commitments on CO2 and cars, nor with further foreseeable progress in vehicle efficiency beyond these commitments and towards the Community objective of 120 g CO2/km.

Review of Directive 1999/30

The problem

Article 9, paragraph 1 (c) of Directive 98/70 requests consideration of “the outcome of the review described in Article 10 of Council Directive 1999/30/EC relating to limit values for sulphur dioxide, nitrogen dioxide and oxides of nitrogen, particulate matter and lead in ambient air”.

Directive 1999/30/EC relates to limit values for sulphur dioxide, nitrogen dioxide and oxides of nitrogen, particulate matter and lead in ambient air. That Directive contained a requirement for a review, in particular with respect to limit values. This review took place as part of the Clean Air For Europe (CAFE programme) which has led to the Communication on a Thematic strategy on air pollution[15].

Underpinning this work is the CAFE baseline[16]. This was established to indicate the nature and extent of air quality problems. Part of the work illustrates which Member States would have difficulties meeting the requirements of the National Emission Ceiling Directive. The baseline shows that for NOx, ten Member States are projected to fail to meet the limits for 2010. These are Austria, Belgium, Denmark, France, Germany, Ireland, Luxembourg, Netherlands, Spain and Sweden. In 2000, 60% of NOx emissions were estimated to come from mobile sources.

The Thematic Strategy recommended that:

- there should be no change to existing air quality limit values;

- new standards and objectives should be established for fine particulate matter (PM2.5);

- vehicle standards should address PM2.5 emissions and NOx from diesel cars and vans.

Sulphur dioxide and lead pollutant emissions are no longer a major source of concern from road transport. The question of the sulphur content of diesel, which is primarily of concern because of its effects on engine and after-treatment systems is addressed in section 4.7 of this Impact Assessment. Therefore for the foreseeable future, the main challenges from road transport for air quality attainment will be NOx and PM emissions.

It had been planned to prepare a questionnaire based on the outcome of the replies to the EURO 5 questionnaire and circulate it to Member States and stakeholders concerning whether fuel parameters needed to be modified. However, the replies to the Euro 5 questionnaire contained no requests for a review of fuel parameters other than sulphur and it was decided to wait for inputs from stakeholders.

CONCAWE has stated that data showing the influence of fuel quality on emissions of advanced vehicles is very limited. Diesel vehicles equipped with particulate traps are insensitive to fuel quality as far as particulate emissions are concerned. Sulphur is the only parameter that seems to still have a significant influence on particulate emissions, especially in terms of particle numbers, and this aspect is discussed in section 4.7. NOx emissions are typically dependent on engine parameters and are affected to a limited extent by fuel quality. CONCAWE therefore believes that further modification of the fuel specifications would not lead to significant environmental benefits.

ACEA has presented some data showing the role fuel can play in reducing emissions. However, the fuels referred to were produced with processes such as gas to liquid (Fischer-Tropsch) conversion. Fischer-Tropsch diesel is currently only available in small quantities. In the long term they might play a more significant role, particularly as an advanced biofuel. ACEA asked for the introduction of Class 4 fuel specifications outlined in the WWFC discussed in section 4.1.

A number of stakeholders stated that any change to the fuel specifications should not lead to any deterioration in environmental performance.

Other stakeholders have stated that there are no requirements leading to a need for a change of any of the fuel parameters.

Lead

There is no need for any further action since the use of lead is prohibited in petrol except for specialist old vehicles. This aspect is therefore not considered further.

Sulphur

The dates for achieving 10ppm have recently been fixed and confirmation of the end date for 10ppm sulphur diesel is considered in section 4.7. This aspect is therefore not considered further here.

NOx

NOx is formed as a product of combustion due to the presence of nitrogen and oxygen in air. Higher combustion temperatures lead to increased NOx emissions. Issues associated with the effect of ethanol on NOx emissions are discussed in section 4.14.

For petrol engined vehicles NOx emissions are mainly controlled with three way catalysts. Aromatic content is reported by CONCAWE to be the main petrol parameter affecting NOx emissions although the effect is complex and it is unclear that any change in this parameter would result in lower emissions.

For diesel, the WWFC claims that reducing total aromatics content leads to lower NOx emissions. ACEA reports that a lower T95 leads to lower NOx emissions for HDVs but an increase for LDVs. However NOx emissions are typically affected to a very limited extent by fuel quality and mainly depend on engine parameters like injection advance. EPEFE tests showed a wider variation in NOx emissions between engines than changes caused by fuel quality.

These various factors point to the desirability of tighter engine emission controls as the way to further reduce NOx emissions rather than changes to the fuel specification. In this context, the WWFC reports tests on NOx conversion technologies that indicate that when these technologies are in use there may be benefit for such technologies to reduce sulphur levels below 10ppm.

Particulate matter

Particulate matter emissions from combustion engines arise either from incomplete combustion or secondary formation from sulphates. The main drivers of PM emissions related to fuel quality are density, sulphur content and PAH content. WWFC reports that a larger proportion of heavy components appears linked to PM emissions.Lower T95 is reported to lower LDV PM emissions.

Policy options

The outcome of the review implies a need to ensure that any changes do not lead to increasing NOx or PM emissions. Previous publications have provided some information on the linkage between different fuel parameters and these pollutant emissions. For petrol CONCAWE states in the conclusions of a report[17] that:

- A reduction in fuel volatility, representing the combined effects of vapour pressure, E70 (38% v/v to 22% v/v) and E100, had no consistent effect on NOx emissions, increased HC across all vehicle technologies (10%), but decreased CO emissions in two cars.

- A reduction in FBP from 197ºC to 176ºC increased NOx emissions in one car but had no significant effect in the others. HC emissions were directionally reduced (9%) and CO emissions directionally increased (20%), with significant effects in both cases in two cars.

- A reduction in aromatics content from 38% v/v to 26% v/v showed conflicting effects, increasing NOx emissions in two cars, decreasing in the others, but the effects were significant only in one vehicle. Reducing aromatics increased HC emissions in the two lean DI cars but showed the opposite effect in the MPI car.

- A reduction in olefins content from 14% v/v to 5% v/v gave no significant improvement in NOx, HC or CO emissions in any of the cars.

- The stoichiometric and lean DI vehicles showed a similar response in PM emissions to changes in fuel quality. Lowering FBP and lowering olefins content gave a reduction in PM emissions whereas lowering aromatics and volatility showed no significant benefits. PM emissions from the advanced MPI car, which is more representative of the current fleet, were very low on all fuels tested and insensitive to fuel changes.

In a further paper[18]on PM emissions CONCAWE states in the conclusions that for diesel:

- In the advanced engine technologies, fuel effects other than sulphur on particulate emissions were small in absolute terms.

while for petrol it is stated that:

- There was no clear short-term effect of gasoline sulphur content on the particulate emissions from direct-injection gasoline vehicles.

The WWFC links sulphur, metallic additives and detergents parameters in petrol to NOx emissions. The latter two parameters are addressed in sections 4.12 and 4.11 respectively. For diesel the WWFC refers to cetane, aromatics, density and sulphur, while PM emissions are linked to polyaromatics, density and sulphur. The density and sulphur parameters are addressed in section 4.13 and 4.7 of this Impact Assessment respectively.

Analysis of impacts

Most stakeholders have not indicated any desire for the fuel specifications related to these pollutants to be modified for environmental or health reasons.

CONCAWE has provided experimental evidence which does not appear to provide convincing evidence of benefit from changing the fuel parameters tested.

PM

For particulate matter there is a difference of opinion between the main stakeholders. CONCAWE believes that beyond 10ppm sulphur, fuel parameters have little effect on PM emissions when a particulate trap is employed. On this assumption the rate at which non trap equipped vehicles are phased out would determine whether or not there is justification for action on any other parameter that could affect PM emissions.

The increasing availability of 10ppm sulphur will lead to lower PM emissions, particularly from older vehicles. Tighter vehicle emission limits are likely to lead to the use of more sophisticated emission control equipment which will reduce the impact of most fuel parameters on PM emissions.

NOx

In particular with a view to reaching ambient air limit values for NO2 in the future, further tightening of vehicle NOx emission requirements is being considered. However, there does not appear to be convincing evidence that adjusting any fuel parameter would conclusively achieve this.

Further evidence would need to be presented on the costs and benefits of the change and a comparison with equivalent costs and benefits from a change in vehicles.

Comparing the options

The evidence does not appear to point clearly in the direction of any particular characteristic of either petrol or diesel that could be changed to further reduce PM or NOx emissions.

Preferred action

It is clear that for lead, no further action is required. For sulphur, no further action is required beyond a final decision on the end date for 10ppm diesel discussed in section 4.7.

For PM, the fuel characteristics should not be modified in a direction that drives PM emissions eg by increasing density. However, there is currently an absence of convincing evidence of further changes in the fuel specification that would reduce PM emissions, or that this would provide the most cost effective approach.

For NOx, the fuel characteristics should not be modified in a direction that leads to increased NOx emissions. There is currently an absence of convincing evidence of further changes in the fuel specification that would reduce NOx emissions, or that this would provide the most cost effective approach.

Polycyclic Aromatic Hydrocarbons

The problem

Article 9, paragraph 1 (b) requests the Commission to consider “the implications of new Community legislation setting air quality standards for substances such as polycyclic aromatic hydrocarbons”.

Certain Polycyclic Aromatic Hydrocarbons (PAHs) such as benzo(a)pyrene (BaP) are considered to be carcinogenic. PAHs are known to be emitted in vehicle exhausts and a maximum limit of 11% PAH in diesel fuel is established by Directive 98/70 annex IV.

In its 2001 proposal to amend Directive 98/70, the Commission stated in paragraph 5.1.1

There has been concern over human exposure to Poly Aromatic Hydrocarbons PAHs) in air. Diesel vehicle exhaust is known to contain PAHs and attention has focussed, therefore, on the levels of PAHs in diesel fuel. The relationship between the PAHs in diesel fuel and in the exhaust gases was not studied in the EPEFE programme. However, a review of the available literature regarding fuel quality and PAH emissions has been published by CONCAWE. Several studies have demonstrated that PAHs are formed during the combustion process (“pyrosynthesis”).

Emissions testing in heavy-duty engines showed that fuels containing low levels of PAHs produced similar emissions of PAHs compared to high PAH containing fuels when other fuel parameters were left unchanged. Other studie s comparing a reference diesel fuel (based upon EN 590) and a Swedish Class I diesel fuel have shown apparently larger contributions from fuel-borne PAHs based upon the total mass of PAHs emitted. However, fuel parameters other than the PAH content were also changed significantly. The CONCAWE report also describes the positive impact of after treatment technologies. These can reduce the emissions of PAHs from diesel engines by between 60-80% even with fuels containing 0.05% sulphur.

The proposal also noted that it was estimated that road transport would in 2010 contribute less than 10% of total PAH emissions.

In the Commission's position paper on PAH[19] it was stated that: New vehicle emissions regulation ('EURO IV') will, in time, further reduce particulate emissions too; this will result in further PAH reductions. The effect of these measures is hard to predict.

The fourth daughter Directive[20] addressing the ambient air quality related to PAH has recently been adopted. Since the proposal for this Directive was under discussion during the CAFE process, it was not felt necessary to consider this issue further within CAFE which instead focussed to a large extent on PM and ozone. The Directive sets an air quality target for BaP and requires monitoring of a number of other PAHs. The Communication on a Thematic Strategy on air pollution does not make specific reference to PAH emissions.

The Directive requires monitoring of PAH concentration and deposition and sets a target value for BaP to be attained where possible from 2012 on. The Directive itself comes into force in 2007 and is due to be reviewed in 2010. In the absence of consistent Community-wide information on PAH concentrations it is unclear whether there is a need for any specific action in the vehicle sector to reduce PAH emissions. However emissions from this sector could contribute to the exceedance of limit values in conurbations. Efforts to reduce vehicle PM emissions will also help to reduce PAH emissions. In this context, the current discussions about Euro 5 and the likely future proposal for Euro VI will influence the future PAH concentrations.

In the context of the stakeholder discussions on the review of Directive 98/70, ACEA has requested a lowering of diesel PAH content. In the current draft of the World Wide Fuel Charter (WWFC), for category 4 fuel, which is intended for use where advanced emission control equipment is in use, a maximum PAH content of 2% is requested. ACEA claim that EU diesel fuel samples show a PAH range of between 2.9% and 6.3%. In contrast EUROPIA state that PAH content does not need to be further lowered because vehicle emission control equipment has a higher effect on PAH emissions than the PAH content of the fuel.

Policy options

The options available are:

- No action

- Tighter limits on PAH in fuels.

The control of vehicle PAH emissions can through exhaust after treatment has not been a subject of this Impact Assessment. Tighter exhaust emission limits are currently under development.

Analysis of impacts

In view of the fact that Directive 2004/107 has only recently been adopted, there is little information available on levels of exposure to PAH. Once this Directive has been in operation for a while there will be more information available on general exposure levels as well as on the need for action on specific sources.

Nevertheless, it is clear that ambient air concentrations of PAH such as BaP in urban areas are affected by traffic emissions and this could lead to problems in achieving the BaP target value. If it is desirable to reduce road transport PAH emissions, it is not clear whether this is better achieved through action on fuel composition or vehicle technology. It is likely that the proposed Euro 5 standard for cars and vans will lead to the fitting of particulate traps to most new cars and vans sold in the EU. This is likely to lead to reductions in PAH emissions.

ACEA requested in stakeholder discussions, the use of the specification referred to as “class 4 fuels” in the WWFC.In the WWFC it is claimed that reducing fuel PAH content reduces engine PM emissions. The WWFC provides some information on fuel PAH effects on PAH emissions indicating a linkage between the two. However, no overall analysis was presented of the environmental benefits that would result from a change in the fuel PAH specification, nor a cost-benefit analysis.

Most stakeholders other than the fuel supply industry did not express any views in relation to PAH content.

CONCAWE has recently reported[21] on the results of a series of tests on PAH emissions from petrol and diesel engined vehicles. CONCAWE’s main conclusions from this work are:

“ Older diesel vehicles showed relatively high exhaust PAH emissions, which increased linearly with higher diesel fuel poly-aromatics content. However, reducing diesel fuel poly-aromatics, even to zero, would not eliminate exhaust PAH emissions, as a significant proportion is combustion derived.

Gasoline vehicles with three-way catalysts or other advanced exhaust after-treatment showed very low PAH emissions compared to the older diesel vehicles. Advanced diesel vehicles with state-of-the-art exhaust after-treatment systems showed very low PAH emissions, close to or below the gasoline vehicles. In these advanced diesel vehicles PAH emissions were so low that there was no longer any sensitivity to diesel fuel aromatics content.

Overall, it is clear that advanced exhaust after-treatment systems, which are being implemented for the control of total hydrocarbon and particulate emissions, are also effective in controlling PAH emissions.”

CONCAWE also claims in a recent paper[22] on the implications for the refining industry of tighter PAH specifications that:

“Depending on the specification level envisaged, reduction of the PAH content of diesel fuel would require between investment of 0.8 G€ at the 6% m/m level and nearly 9 G€ at 1% m/m. The majority of the capex would be for new hydrodearomatisation plants and hydrogen production plants.”

This paper also shows that maximum PAH content could be reduced to 8% at the same time as sulphur content is reduced to 10ppm at no additional cost.

CONCAWE’s work appears to show that even reducing fuel aromatics to zero would not eliminate PAH exhaust emissions and there is a large body of evidence supporting this conclusion. The mechanisms through which PAHs may occur in exhaust gas can be summarised as follows:

a) Survival of fuel PAH during combustion : some of the PAH present in the fuel will not be combusted and be emitted as part of the unburnt hydrocarbons. The survival rate depends on each PAH, on engine design, test cycle and other engine and fuel parameters.

b) Creation of PAH during combustion: experimental and theoretical work indicates that PAHs may be formed during the combustion process by pyrosynthesis from non-PAH, including non