Ethanol in fuel — Our submission to the Dft and their response

Below is the covering letter from the NAWCP to the Department for Transport. This is followed by our submission and finally the emailed response from the DfT

 

●  ●  ●  ●  ●  ●  ●  ●  ●  ●  ●  ●

 

From:  The National Association of Wedding Car Professionals (NAWCP)
1 West Fryerne
Yateley
Hampshire
GU46 7SU
Telephone: 01252 875 222
Email: admin@nawcp.co.uk

 

Mr Michael Wright
Department for Transport
Zone 1/32
Great Minster House
33 Horseferry Road
LONDON
SW1P 4DR                                                                                        24 September 2013

 

Dear Sir

RESPONSE TO THE CONSULTATION PAPER ON THE PROPOSED AMENDMENT TO THE MOTOR FUEL (COMPOSITION AND CONTENT) REGULATION 1999.

The NAWCP has a current membership of 155 (and growing) wedding car business throughout the UK and represents those business on all issues associated with the ownership and operation of vintage classic and specialists vehicles.  Full details of the Association can be found at www.nawcp.co.uk.

Following an established consultation process with all our members the NAWCP offers the attached paper for your urgent consideration.  In particular, while the NAWCP supports the initiative to retain a supply of fuel with an ethanol percentage mix as low as possible, the NAWCP would also wish to impress upon the Government that additional measures are necessary to ensure that owners and operators of vintage classic and specialists vehicles (the vast majority of which are considers by the Government and register accordingly as ‘Historic Vehicles’) are able to maintain their vehicles appropriately for many years to come. Although included in our attached response, the additional measures considered necessary are listed again here for completeness:

  • The extension of the regulation should not be limited to only those filling stations “that have supplied not less than 3 million litres of fuel (petrol and diesel) in the previous year.”
  • Allow fuel companies to supply or continue to supply an amount of ethanol free fuel for the foreseeable future.
  • Ensure that all fuel pumps are clearly marked to indicate the ethanol content of the fuel dispensed.
  • Ensure that information regarding the effects of ethanol in petrol be freely available via a government website so that individuals and business can put in place a strategy to counter the effect of ethanol in older cars.

The NAWCP asks that the Government gives serious consideration to our comments and in particular the additional measures believed necessary to sustain for many years to come the vintage, classic and specialist vehicle wedding car industry within the UK.

.

Attachment: The NAWCP Response to the Consultation Paper on the Proposed Amendment to the Motor Fuel Composition and Content Regulations 1999.

.

Signed: Christopher Hill: Associate of the National Association of Wedding Car Professionals

Authentication: David Jones: President of the National Association of Wedding Car Professionals

.

●  ●  ●  ●  ●  ●  ●  ●  ●  ●  ●  ●

.

The NAWCP Response to the Consultation Paper on the Proposed Amendment to the Motor Fuel Composition and Content Regulations 1999

  1. Background

1.1     The National Association of Wedding Car Professionals (NAWCP) represents 155 (and growing) wedding car businesses on a UK national basis.  The vast majority of UK wedding car businesses operate vintage, classic and older specialist vehicles which, in simplistic terms, have engines that were originally designed for lower grade petrol with lead as the only regular additive.  Many of the vintage, classic and specialist vehicles have since been converted to lead-free petrol or use an additive to replace the lead and as a consequence can run successfully with little further trouble.  However, since the addition of ethanol in petrol, engine and fuel supply problems can and do occur, causing additional expense and lost business time.  Furthermore, while the NAWCP represents wedding car businesses, the issued discussed in the submission are just as relevant to private owners of vintage, classic and specialist vehicles.

2   Vehicle Problems and Environmental Effect

2.1     The NAWCP recognises that ethanol may have the virtue of being a renewable energy source, which, is a good thing if the engine using the fuel with ethanol added is specifically designed to use such fuel, but is not such a good thing if the engine was originally designed for non-ethanol fuel; principally, because of the corrosive nature of ethanol and its ability to absorb moisture and it is the corrosive nature and water absorbency that causes so many problems for vintage, classic and older specialist vehicles. The science behind ethanol blended petrol and its indifferent nature to older engines is well documented so it will not be repeated here, however, suffice to say that even E5 fuel can cause considerable problems over the longer period having a significant impact on the health and safety of us all.  Consider for example the increase in risk to the public of fuel leaks due to ethanol induced corrosion of (older style) fuel lines and tanks.  The more rapid deterioration of fuel pipes (and tank seals in vintage cars where the fuel tank is in the engine compartment) could easily result in petrol being sprayed onto a hot engine component such as the exhaust manifold or engine block.  Furthermore, engine malfunctions caused by incorrect metering of fuel due to ethanol in the petrol may increase the production of oxides of nitrogen in the exhaust fumes.  While modification to vintage, classic and specialist vehicles can sometimes be done, they are expensive and not always conclusive in the longer term.

2.2     Clearly, new vehicles will have a lower ‘carbon footprint’ (after they are built) than older cars, however, arguably, the largest carbon foot print a vehicle makes is during its construction.  Prematurely removing older vehicles from the road sounds attractive, but a well maintained older vehicle, as is the case with our member’s vehicles, will have a far lower detrimental effect on the environment than replacing it with a new vehicle.  Similarly, having to manufacture replacement, ethanol friendly, components for the older vehicles due the ravages of ethanol will also increase carbon emissions, which is the exact opposite of the intend goal of adding ethanol to petrol.  The eventual move, after January 2017, to allow up to E10 for all fuels will only exacerbate the problem in the long term.

3   Additional Problems

3.1     All that said, there can be no doubt that the singular move to extend the availability of E5 fuel, albeit super fuel and consequently considerably more expensive, until January 2017 has some degree of merit, but the proposal limits this availability to:  “filling stations that have supplied not less than 3 million litres of fuel (petrol and diesel) in the previous year.”  Surely, this limitation will cause the problems previously mentioned to be prevalent amongst the older car fraternity living away from the main centres far sooner than January 2017? It is not believed that this is what the government wishes, as once again, it is the exact opposite of the intended goal of adding ethanol to petrol.  Fortunately, it is understood that some fuel supply companies are able to dispense zero ethanol fuel; blending ethanol with the petrol is the final process for the fuel supplier.  It is our understanding that ethanol is added only when the fuel is in the tanker ready to be delivered because if added sooner the ethanol would ‘attack’ the storage tanks in the fuel depot, and it is for this same reason that ethanol cannot be transferred along pipelines.  Consequently, it can unquestionably be a practicable option for zero E rated fuel to be made available to the consumer if legislation so dictated.

4   Conclusion and Additional Proposals

4.1     In sum, the government proposal, while a temporary solution for just part of the problem, has our limited support, but it does not solve the basic and original vehicular and environmental problems created by the addition of any amount of ethanol in petrol.  Consequently, while supporting the basis of the proposed legislation we would also strongly urge the government to take additional actions that would help owners of historic vehicles maintain their vehicles in the longer term for the benefit of all.

4.2     Whilst supporting the need to retain the limitation of a maximum 5% ethanol mix in Super grade petrol it is proposed that the government also:

  • Does not limit the extension of the regulation to only those filling stations “that have supplied not less than 3 million litres of fuel (petrol and diesel) in the previous year.”

4.3     It is further propose that additional legislation be put in place to:

  • Allow fuel companies to supply or continue to supply an amount of ethanol free fuel for the foreseeable future.

  • Ensure that all fuel pumps are clearly marked to indicate the ethanol content of the fuel dispensed.
  • Ensure that information regarding the effects of ethanol in petrol be freely available via a government website so that individuals and business can put in place a strategy to counter the effect of ethanol in older cars.

.

Date: 24 September 2014

Authentication: David Jones: President of the NAWCP

●  ●  ●  ●  ●  ●  ●  ●  ●  ●  ●

—– Original Message —–

From: Biofuels Transport

To: ‘Chris Hill’

Cc: Mariagrazia Luciano

Sent: Tuesday, October 08, 2013 5:20 PM

Subject: RE: Response to the Consultation Paper on the Proposed Amendment to the motor fuel regualtion 1999

Dear Chris Hill MBE

This email is to acknowledge NAWCP’s response to the DfT’s consultation paper on a proposed amendment to the Motor Fuel Composition and Content Regulations 1999 which would extend the current legal requirement for a ‘protection’ grade – for engines that are not compatible with E10 petrol.

We will be analysing the responses received to the consultation carefully and aim to publish a summary of responses in the autumn. Thank you for taking the time and trouble to participate in the consultation exercise.

Your response notes some wider concerns in respect of E10 to which the following information may be helpful.

UK legislation does not prohibit the supply of petrol with no ethanol content, or E0. The Motor Fuel (Composition and Content) Regulations 1999 set a maximum permissible ethanol content of petrol – there is no minimum content. Decisions on whether to supply petrol with no ethanol content are a commercial matter for individual fuel suppliers based on amongst other things demand for that blend.

The Biofuel (Labelling) Regulations 2004 require that pumps dispensing petrol containing more than 5% ethanol must be labelled “Not suitable for all vehicles: consult vehicle manufacturer before use”. This notice must be displayed prominently on any dispenser from which such fuel is sold or offered for sale to the ultimate consumer.

You may also be interested to know that the Department for Transport has supported the development of an industry-led information campaign, co-ordinated by the Low Carbon Vehicle Partnership, which aims to ensure that consumers are adequately informed before E10 starts to be supplied.  This will include how people can access information about the compatibility with E10 of different makes and models by date of manufacture. Some information on E10 including technical guidance is already available in the LowCVP’s website at the following link: http://www.lowcvp.org.uk/e10/faq.asp

Regards

Michael

Michael Wright

Biofuels Regulation Branch
Low Carbon Fuels

Department for Transport
Great Minster House
33 Horseferry Road
London
SW1P 4DR

phone :  020 7944 4378

e-mail   : Michael.Wright@dft.gsi.gov.uk

.


2 Comments

  1. Phil Robertson says:

    Strikes me that this will end up in much the same mess as the “continued” availability of leaded fuel!
    My nearest supplier was more than 30 miles away.
    I suppose we will have to trust to an additive to alleviate the potential problems.

    • david says:

      There are products that have been tested by the Federation of British Historic Vehicle Clubs (FBHVC) to help counteract the detrimental properties of Ethanol. You can find details at http://fbhvc.co.uk/legislation-and-fuels/fuel-information/ They also list additives to help with unleaded fuel. I am not sure of the advisability of using both together and will enquire of the FBHVC if they know of any problems.

Leave a Reply

Your email address will not be published. Required fields are marked *