Fuel quality vapour pressure derogation
– Directive 98/70/EC
According to Article 3 (4) and (5) of Directive 98/70/EC of the European Parliament and of the Council relating to the quality of petrol and diesel fuels, as amended by Directive 2009/30/EC, Member States with low ambient summer temperatures, among these Denmark, may request a waiver to increase the vapour pressure of petrol during the summer period to a maximum of 70 kPa.
The approval of a waiver is subject to the assessment of the Commission taking into consideration the socio-economic-, health- and environmental consequences of a waiver, including the possible lack of compliance with Community legislation resulting from a higher vapour pressure. The core of the assessment consists of a comparative analysis of the situation on one hand with and on the other hand without the requested waiver.
With this notification, Denmark requests permission to continue using the currently applied summer period vapour pressure limit of 70 kPa until the end of year 2020, with the possibility of a prolongation, should the current situation, as described in the sections below, remain unchanged.
It is essential for Denmark to maintain the current waiver in order to avoid having to add MTBE (Methyl tert-butyl ether) or other ethers to petrol in Denmark which would otherwise be necessary in order to comply with the summer period vapour pressure limit of 60 kPa as stipulated in Annex I of Directive 98/70/EC.
MTBE and ethers in general are unwanted as additives to petrol in Denmark due to concerns for ground water contamination in cases of spills and leaks. In Denmark, unlike any other Member State in the EU, ground water is used un-rinsed as drinking water. As a result, even small spills or leaks of petrol containing MTBE or other ethers will make the ground water useless as drinking water due to the very unpleasant smell and taste of these additives.
Currently, MTBE is only added to octane 98 petrol in Denmark. Octane 98 petrol, though, only makes up less than 0.2 % of the total sale of petrol in Denmark and is only offered for sale at a very limited number of service stations.
However, without a waiver it would also be necessary to add MTBE or other ethers to octane 95 and 92 petrol. With octane 95 and 92 petrol making up around 99.8 % of the total sale of petrol in Denmark and being offered for sale at every service station in the country, the risks of a ground water contamination happening will be far greater, despite taking all precautionary measures to prevent spills or leaks. Denmark wishes to eliminate this risk altogether.
The continued use of a vapour pressure of 70 kPa during the summer period is therefore an important precondition of the continued marketing of MTBE-free octane 95 and 92 petrol in Denmark and, consequently, to secure the continued supply of drinking water within the country.
Also, as shown in the following sections, allowing a higher vapour pressure of 70 kPa will not result in a lack of compliance with Community legislation on air quality or air pollution, including the relevant limit values and emissions ceilings.
Furthermore, studies show that the use of a higher vapour pressure (70 kPa) in Member States or regions with cool summers, among these Denmark, does not result in higher VOC emissions in these Member States than in southern European Member States with a vapour pressure of 60 kPa.
In general, Denmark supports as low petrol vapour pressure limits as possible to minimize evaporative emissions. However, the vapour pressure limits ought to be adapted to the prevailing ambient temperatures. Member States or regions with cool summers should therefore be allowed the use of a higher vapour pressure during the summer period, especially in cases where it is of particular importance due to environmental considerations in a Member State.
TRUE VAPOUR PRESSURE (TVP) AND DRY VAPOUR PRESSURE EQUIVALENT (DVPE)
Dry Vapour Pressure Equivalent (DVPE) is a convenient way to measure the vapour pressure in petrol under laboratory conditions. The DVPE test involves pouring petrol into a bottle that is fitted with a closed cap and pressure gauge, heating the bottle to +37.8 ºC and recording the pressure of the vapour (in kPa) inside the bottle.
However, since the vapour pressure is closely associated with the actual meteorological temperatures, vehicle operation and evaporative emissions depend more strongly on the True Vapour Pressure (TVP) than on the DVPE.
Figure 1.
Figure 1 shows the correlation between the vapour pressure in petrol and the prevailing ambient temperatures. As shown, if the temperature on a typical summer day:
· Is 17.8 ºC in Denmark, then the TVP will be about 30.5 kPa at a nominal 70 kPa DVPE.
· Is 24.2 ºC in a southern European country, then the TVP will be about 34.7 kPa at a nominal 60 kPa DVPE.
In other words, the TVP in Denmark will be lower at a nominal 70 kPa DVPE than the TVP in a southern European country at a nominal 60 kPa DVPE on a typical summer day.
INFORMATION REGARDING THE SUPPLY OF PETROL IN DENMARK
In the Guidance note, the Commission requests information on various aspects of the supply of petrol. There are two refineries in Denmark. The total amount of petrol produced in Denmark in 2009 was approximately 2,600,000 cubic metres (m3) petrol.
In 2009 the consumption of petrol in Denmark was approximately 2,200,000 m3 – as shown in table 1.
Table 1: Consumption of petrol in Denmark
RON 92 / 453,000 m3RON 95 / 1,748,000 m3
RON 98 / 3,000 m3
Total / 2,204,000 m3
There has been a decrease of around 2 – 4 % in the consumption of petrol over the past years; this is expected to continue in the coming years. In table 2 a prognosis until 2015 is shown with a yearly decrease in consumption of around 2.5%.
Table 2: Estimated consumption of petrol in year 2010 to 2015
m3 / 2010 / 2011 / 2012 / 2013 / 2014 / 2015RON 92 / 441,675 / 430,633 / 419,867 / 409,371 / 399,136 / 389,158
RON 95 / 1,704,300 / 1,661,693 / 1,620,150 / 1,579,646 / 1,540,155 / 1,501,651
RON 98 / 2,925 / 2,852 / 2,781 / 2,711 / 2,643 / 2,577
Total / 2,148,900 / 2,095,178 / 2,042,798 / 1,991,728 / 1,941,935 / 1,893,387
As mentioned, the two Danish refineries produce approx. 2,600,000 m3 petrol per year. More than half (1,400,000 m3) is sold in Denmark while the rest is exported mainly to Sweden, Norway and England. The rest consumed in Denmark (800,000 m3) is imported mainly from Sweden and Norway.
Table 3: Export and import balance 2009
Petrol supply in Denmark 2009 / m3Production / 2,600,000
Import / 800,000
Export / 1,200,000
Petrol supplied to retail sites / 2,200,000
Of the total amount of petrol supplied to retail outlets in 2009 (2,200,00 m3), 575,000 m3 or about 25 % is so-called summer grade petrol – June to August – that does not meet the summer period vapour pressure limit of 60 kPa. This is the amount of petrol covered by the Danish request for the continued use of a higher vapour pressure of 70 kPa.
During the summer period, the majority of the exported petrol has a vapour pressure of around 63 kPa – so when adding 5% bioethanol the vapour pressure increases to 70 kPa. The petrol is only exported to countries where a higher vapour pressure is allowed during the summer period.
Outside the summer period, the petrol being sold in Denmark has a vapour pressure of around 95 kPa. The same goes for petrol being exported in this period.
Only one company added bioethanol to 95 octane petrol in 2009 – the maximum ratio was 5%. This corresponds to 0.6 % v/v bioethanol of the total petrol consumption in Denmark.
Vapour pressure limits in Denmark
The Danish vapour pressure requirements are outlined in Table 2 below.
Table 4: Vapour pressure limits in Denmark
Vapour pressure / Summer / WinterVapour pressure, DVPE, min, kPa / 45 / 65
Vapour pressure, DVPE, max, kPa / 70 / 95
The summer period in Denmark is defined as the period between 1 June – 31 August and the winter period as between 1 October – 30 April. The periods in between are transition periods where both summer and winter qualities of petrol are allowed as the quality of petrol needs to be changed 2-3 weeks prior to the change in period between winter and summer.
DIRECT SOCIO-ECONOMIC PROBLEMS
Since 2005, Denmark has permitted petrol with a vapour pressure of 70 kPa during the summer period in order to make it possible for the Danish refineries to produce petrol without MTBE or other ethers when the maximum allowed content of aromatics was reduced from 42 to 35 %.
If the requested waiver is not granted and the maximum vapour pressure allowed for petrol during the summer period is 60 kPa, the refineries will not be able to guarantee the continued supply of octane 95 and 92 petrol without added MTBE or other ethers.
As developed below, the addition of other components to petrol instead of MTBE, such as alkylat or isooctane, in order to lower the vapour pressure is not considered a possibility at present.
Alternatives to the addition of MTBE (or other ethers)
Isooctane is not considered a commercially available feedstock in Europe and the Danish refineries would, consequently, have to rely on the import from refineries outside of Europe. This would entail a risk in relation to the security of supply which could hamper the production of petrol with a lower vapour pressure (60 kPa) and result in a shortage of supply of petrol to the Danish market in periods during the summer.
The same would apply in relation to the import of alkylat as the refineries producing alkylat in Europe are using the bulk of it in their own production of petrol. As a result, the Danish refineries would also have to rely on the import of alkylat from refineries outside of Europe.
Production of alkylat
In order to secure the access to the required amounts of alkylat and, ultimately, to secure the supply of petrol with a maximum vapour pressure of 60 kPa during the summer period, the Danish refineries would have to start up their own production of alkylat.
However, this would require an upgrade of existing refineries with alkylat production facilities. Such upgrade would involve a likely cost of one billion DKK (approximately 150 million Euros). Any production of alkylat would, given the size of the Danish refineries, be too insignificant to make such an investment profitable and, as a result, the competitiveness of the refineries would suffer.
Furthermore, the Danish refineries do not have the required capacity to produce the raw material (alkanes) needed for the production of alkylat and, thus, would have to rely on the import from refineries abroad, primarily from refineries outside of Europe. This would again entail a risk in relation to the security of supply and, as a result, the refineries would not be able to guarantee the supply of petrol with a lower vapour pressure (60 kPa) during the summer even if the required investments in production facilities were made.
Import and export of petrol
Consequently, it would be necessary to import around 575,000 m3 of petrol with a maximum vapour pressure of 60 kPa and export an equal amount to countries where a higher vapour pressure is allowed. The transportation involved would, as a side effect, result in an increase in CO2 emissions.
Contact has been made to the refineries currently supplying the Danish market with petrol during the summer period and these refineries will not be able to guarantee the supply of petrol with a lower vapour pressure (60 kPa) in the amounts required. As a result, Denmark would have to rely on the import of petrol from refineries abroad.
The extent of the problems that Denmark will be facing in relation to the import of petrol with a lower vapour pressure (60 kPa) also depends on whether the other Member States with low ambient summer temperatures as listed in Article 2 (5) of Directive 98/70/EC will be granted a waiver. If not, these Member States, including Denmark, will find it difficult to secure the supply of petrol with a lower pressure in the amounts required due to demands exceeding the supply in Europe.
Furthermore, this will most likely result in an excess of petrol with a vapour pressure of 70 kPa in Europe, since neighbouring countries have also permitted petrol with a vapour pressure of 70 kPa during the summer period. Europe already has an over capacity of petrol production and is relying on the supply outlet mainly to the United States. The demands for petrol in the US has, however, been reduced in recent years due to an increase in the content of ethanol in petrol and it would, consequently, be difficult to find a market for excess petrol.
Conclusion
If the requested waiver is not granted and the maximum vapour pressure allowed for petrol during the summer period, as a result, is 60 kPa, the petrol used during the summer period in Denmark would have to be imported from refineries abroad or, alternatively, expensive components, such as isooctane or alkylat, would have to be imported from refineries outside of the EU. This would entail a risk in relation to the security of supply of petrol to the Danish market during the summer period.
COMPLIANCE WITH COMMUNITY LEGISLATION ON AIR QUALITY AND AIR POLLUTION
National emissions ceilings in 2010
Directive 2001/81/EC of the European Parliament and of the Council on national emission ceilings for certain atmospheric air pollutants (NEC-Directive) has been transposed into Danish legislation by Statutory Order no. 21 of 8 January 2003. The national emission ceiling of NMVOC’s from 2010 is set to 85000 tonnes.