A submission by Ireland to. European Commission, Secretariat-General, 1049 Brussels. Fuel Quality Vapour Pressure derogation Directive 98/70/EC

Transcription

1 A submission by Ireland to European Commission, Secretariat-General, 1049 Brussels Appendices Document Appendix 1: Ireland Situation in Relation to Ozone Pollution Appendix 2: Benzene in Atmosphere Appendix 3: True Vapour Pressures v/s Test Vapour Pressures Appendix 4: Notes on Impacts on Oil Refining and Consumers Appendix 5: Transport Fuel Projections Data Sources: The data sources used to support this Submission and Appendices include: Department of Environment Heritage and Local Government (DoEHLG) Environmental Protection Agency (EPA - Ireland) European Environment Agency - Ozone Maps (EEA) Sustainable Energy Authority of Ireland (SEAI) The Irish Petroleum Industry Association (IPIA) ConocoPhillips (Whitegate Oil refinery) (COPI) The Revenue Commissioners The United Kingdom Petroleum Industry Association (UK PIA) Page 1 of 8

2 Appendix 1: Ireland Situation in Relation to Ozone Pollution As can be seen from the attached map from the EEA website, Ireland, together with Finland and Latvia are the only Member States whose entire territory is shown as meeting the long term objective for Protection of Vegetation from Ozone (i.e. the long term objective). This is a function of: Lower summer temperatures in Ireland than many Member States; Low population density and resultant lower concentrations of VOCs; Peripheral location on western-most edge of Europe. Source: EEA website: This map demonstrates that Ireland is one of the few Member States which has the lowest risk of negative impact from ozone produced from the reaction of VOCs in the atmosphere. Others low risk areas include Finland, Latvia and also large areas of UK including all of Wales and Scotland and much of England. This position is corroborated by the ozone monitoring conducted by the EPA in Ireland. See Figure 14 extracted from EPA s 2008 Air Quality Report overleaf. Page 2 of 8

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4 Appendix 2: Benzene in Atmosphere in Ireland (Source EPA Report Air Quality in Ireland 2008 ) Ireland is also well below the air quality thresholds for benzene. The following extract is from the Air Quality in Ireland 2008 report by the EPA. Quote Unquote. Note: Zone A (Dublin) and Zone B (Cork) represent the two largest urban areas in Ireland and both have significant oil storage terminals. In addition, Cork is the location of Ireland s only oil refinery. Page 4 of 8

5 Appendix 3: True Vapour Pressures in Different Member States The evaporative emissions associated with vapour pressure depend directly on the True Vapour Pressure. This in turn is determined (a) by the actual ambient conditions at any time and (b) is also a function of the test vapour pressure at the standard test conditions of C (100 0 F) as specified in the Fuels Quality Directive. Because Ireland has lower summer temperatures compared to Member States in Southern Europe, for example, the true average monthly True Vapour Pressures (TVP) in Ireland are likely to be such that for long periods of the summer the TVP of a 70 kpa petrol sold in Ireland will be lower than the TVP of a 60 kpa petrol in use in hotter Member States. The graph below was produced by the UK oil industry and shows the relationship between the True Vapour Pressures for petrol of 60 kpa and 70 kpa test pressures at the prevailing temperatures in UK, Italy and Sweden. This shows how the True Vapour Pressures in different countries would compare for petrol of differing test vapour pressures. The same relativities would be expected for Ireland which is closest to the UK in terms of location and climate. ) a P (k P V T Sweden (70 kpa) UK (70 kpa) UK (60 kpa) 15 May Jun Jul Aug Sep Italy (60 kpa) Figure 1: Selected True Vapour Pressure (Concawe Report 97/53) The graph above shows that:- Petrol in UK with a 60 kpa DVP (the green bar) would if the 60 kpa limit were adopted, have an average true vapour pressure which would fall well below those in warmer countries Page 5 of 8

6 in Southern Europe such as Italy in all months from May to August inclusive for petrol with the same test vapour pressure of 60 kpa. It is also noteworthy that a UK petrol meeting a 70 kpa (Dry Vapour Pressure test) limit would still exhibit a lower average true vapour pressure than that of a 60 kpa (test) petrol sold for use in a hotter country as exemplified by Italy. Petrol with a 70 kpa specification in UK is seen to have a similar TVP as 70 kpa petrol in Sweden. Since VOC emissions are a function of TVP (and not test VPs conducted at C) it is reasonable to apply the higher vapour pressure limit in those countries with lower summer temperatures (as provided for in the Directive) while using a lower kpa specification in those countries with higher ambient temperatures in summer. This is especially relevant in view of the fact that there is a strong correlation between those countries with lower summer temperatures and those areas shown to have the lowest ozone levels and to be less than or equal to the long term objective for the protection of vegetation according to the EEA map entitled Ozone Page 6 of 8

7 Appendix 4: Impact of 60 kpa limit on Oil Refining Costs to Ireland Table 3: Estimated Cost to Irish Economy of supplying 60 kpa limit for summer sales of petrol. (Based on UKPIA research) Parameter Annual Refinery Gasoline Production (UK) & Total annual sales in Ireland (kt/yr) Projected annual additional costs to UK and Ireland of supplying 60 kpa petrol. *Source: UKPIA Costs to UK Refiners* (based on annual Consumption kt/yr) 16,000 kt/yr UK refinery throughput 150 million per year (UK PIA research : additional refining costs are made up of 104 million in additional Operating costs and 44 million being the annualised capital cost for new refinery processing equipment) Scale Factor UK Demand to Ireland s Petrol Demand 9.7 1,650 kt Pro-rata Cost to Ireland s Economy of 60 kpa limit (Based on Total Demand kt/yr) million (Converted from GBP to at 1.0 = 0.85 GBP) Page 7 of 8

8 Appendix 5: Transport Fuel Projections In December 2009, the Sustainable Energy Authority of Ireland (SEAI) published a report entitled Energy Forecasts for Ireland to 2020 for all energy inputs to Ireland including projections on the sales of gasoline. The Authority modelled a number of scenarios including a scenario which they entitled Policy Scenario which reflects targets in the Government s Energy White Paper (2007) and incorporates the outcome of a range of policies and measures on energy efficiency, renewable energy and a Government target for electric cars by Current policy measures, such as those relating to vehicle registration tax (VRT) and annual motor tax, are aimed at encouraging a switch to diesel cars. Oil products in general are set to grow over the based on a decline of 2.9% per annum in the period , followed by annual growth of 2.3% thereafter. Due to switching to diesel and electric vehicles, the growth in petrol sales will be significantly lower than the overall growth in transport fuels as a whole as can be seen in the table from the SEAI 2009 Report. In fact petrol sales in 2020 are projected to be marginally below those in A national target has been set of 250,000 electric vehicles to be in use in Ireland by 2020 and the roll-out of the EV charging infrastructure has begun. The table from the SEAI report of December 2009 is reproduced below and indicates that petrol consumption in Ireland will decrease sharply between 2008 and 2012 before increasing at ~ 1.4% per year from 2012 out to Petrol sales in 2020 are nevertheless projected to be ~ 1.8% lower than the actual sales recorded in Source: SEAI 2009 Page 8 of 8