Review of Directive 98/70 – non-paper 3

End date for 10ppm sulphur diesel

Requirement in Directive 98/70:

Article 9, paragraph 1 (a) 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 problem

10ppm sulphur diesel is an enabling fuel for higher vehicle efficiency due to lower need for DPF regeneration. Reducing sulphur content also leads to benefit in SO2 and PM emissions. Sulphur can poison De NOx after treatment systems.

The Directive contains a provisional end date for 10ppm sulphur which may be confirmed or modified on the basis of an assessment of the various contributory factors. The JRC has been asked to carry out an analysis of these factors and report.

Stakeholder views

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 and permits use of NOx reduction technologies.

CONCAWE has recently published[1] 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 €3.2G and 1.1-1.4Mt CO2 per year.

Analysis

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. As the fleet renews slowly, and there is no data on the technologies at present the impact of this class of vehicle was not included. However, even a small effect would be significant.

The main conclusions from JRC’s 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 10 ppm 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.
  • 10 ppm 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, but by reducing regeneration frequency it may have an impact on these vehicles’ fuel economy.

Fuel quality monitoring shows a gradual roll out of 10ppm sulphur diesel across the EU. Monitoring data for 2003 shows that 10ppm sulphur fuel accounted for around 25% of all EU diesel sales. While full figures are not yet available for 2004 it would be reasonable to assume that the proportion in the market will be higher.

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. 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.

Proposed action

In view of the identifiable benefits and progress made so far the end date for 10ppm sulphur in diesel should be confirmed as 1 January 2009.

[1] The impact of reducing sulphur to 10ppm max in European automotive fuels an update; CONCAWE 8/05