| Property |
NZS 7500 requirements |
Proposed amendments to PPSR as in Discussion Document |
Submissions |
Ministry comment |
Final Recommendation – Amendments to Schedule 3 of the PPSR |
| Biodiesel content |
5% by volume biodiesel max |
5% by volume FAME max |
Several submitters do not support a limit of 5% by volume biodiesel being placed on blends for retail sale, as they would like the flexibility to sell higher blends via retail sale (but recognise that these would need to be labelled). The arguments for this are largely based around consumer choice and supporting the domestic biodiesel industry. |
There is a lack of vehicle manufacturers who will support biodiesel blends above 5% by volume. It is also unlikely that the majority of biodiesel blends of higher than 5% by volume would be compliant with the diesel specifications. Specifications for retail sale of higher level biodiesel blends will need to be developed when the demand and supply for these fuels increase. In the interim, higher blends can be supplied to compatible fleets via non-retail sale. |
5% by volume Fatty Acid Methyl Ester max, which meets the B100 specifications. EN 14078 |
| Total contamination test method |
EN 12662 but PPSR ASTM D6217 |
EN 12662 |
Majority of submitters support the PPSR being amended from testing particulates with ASTM D6217 to testing total contamination with EN 12662 or IP 440 which is equivalent (same limit for both applies). |
|
IP 440 |
| Cold flow performance |
Winter +2ºC CP max, -6ºC CFPP max Summer +4ºC CP max |
Option for relaxing specs in Auckland / Northland (petroleum diesel and B5 blends) |
Submitters generally supported a relaxation of the CP requirements in summer provided that this is justified by climate data. Gull New Zealand Ltd do not support having geographically different cold flow requirements. as they believe that it will place them at a disadvantage against the four major oil companies. Gull only draws fuel from one source (i.e. Mt Maunganui), and to continue to supply areas north and south of Auckland all fuel will need to meet the more stringent requirements. Whereas the four major oil companies will have the option to supply separate stock to Auckland/Northland. The higher the cloud point, the lower the cost of the diesel. |
A review of the climate data showed that the current requirement is more stringent than necessary for Auckland/Northland in summer. Climate data also indicates that there is a risk of waxing in the central volcanic plateau with diesel that meets the current regulated CP for summer. The purpose of the regulations is to specify absolute minimums and set an overriding ‘fit for common purposes' requirement. Relaxing the CP specification in this region will facilitate the blending of biodiesel into existing diesel stocks, reducing the need for a separate diesel blendstock. In general, blending biodiesel into diesel at the 5% by volume level increases the CP of the fuel by 2 to 3ºC. |
Winter no change Summer: Auckland/ Northland CP +6ºC max; rest of country CP +4ºC max |
| Filter Blocking Tendency (FBT) |
Fuel shall be of acceptable filterability so that it is fit for common purposes (acceptable filterability can be expected if the result is less than 2.5) |
No amendment to Schedule 3 of the PPSR, i.e. 2.5 max; fuel must be of acceptable filterability so that it is fit for common purposes. |
Several submitters are of the view that the FBT requirement should not apply to biodiesel blends due to the sensitivity of the test and the problems fuel made from tallow is experiencing in meeting the 2.5 limit. |
There is not enough evidence to suggest that an FBT limit above 2.5 would not have a negative impact on vehicle operability. It would be prudent to require biodiesel blends to meet the current FBT requirement until it is better known what the affects of a higher limit are on vehicle operability. |
No amendment to Schedule 3, i.e. 2.5 max; fuel must be of acceptable filterability so that it is fit for common purposes. |
| Formic, Acetic and Propionic Acids |
No spec |
No spec |
All but one submission supported. |
JAMA and MIA concerns should be addressed if IP for B100 oxidation stability is minimum 10 hours. |
No amendment to Schedule 3, i.e. not specified. |
| Carbon Residue (on 10% distillation) |
0.25% m/m |
0.20% m/m |
Two submitters are of the view that the carbon residue (on 10% distillation) should be 0.3% m/m. |
Cabinet considered the carbon residue limit for petroleum diesel in December 2006 and approved a limit of 0.20% m/m. |
No amendment to Schedule 3, i.e. 0.20% mass max |
| Cetane Number Test Method |
ASTM D6890 ISO 5165 ASTM D613 |
ASTM D613 |
Comments as for B100. |
Comments as for B100. Cetane index (ASTM D976) is not applicable for blends containing biodiesel. |
Cetane Number: ASTM D613 or ASTM D6890. Cetane Index: ASTM D976 (not suitable for biodiesel blends) |