The Canadian Trucking Alliance (CTA) is voicing concern over the impact of biodiesel on engine operability and durability.
CTA said the situation has led it "to the inescapable conclusion that the Government of Canada’s current plan to introduce a biodiesel mandate is flawed and needs to be changed."
According to David Bradley, CTA chief executive officer: "The engine manufacturers have not and cannot provide assurances that biodiesel will not expose the Canadian trucking industry to engine problems, increased costs, and possibly the voiding of engine warranties."
One problem with the government’s plan is the averaging provision contained in the 2006 Notice of Intent --- which calls for all diesel fuel sold in Canada to contain 2% biofuel content. This provision will provide flexibility for the suppliers and manufacturers of biofuel but will force the biofuel content sold in on-road diesel well above the B2 range into B5 and higher levels. These types of biodiesel fuel levels pose engine warranty and possibly cold weather operability issues for most engines on the road today, CTA said.
"Under the averaging approach the business interests of biodiesel producers and the petroleum industry all have some level of protection," says Bradley. "Truck engine manufacturers provide no assurance that any biodiesel fuel sold above B5 will not cause operability problems for most new heavy truck engines. The engine manufacturers have told this to all the stakeholders in the biodiesel debate including the federal government."
Manufacturers foresee few warranty problems using biodiesel up to B5 in most 2002 or newer model year truck engines so long as the fuel is blended and manufactured to specific standards. However, this matter is less clear in pre-2002 engines and the matter of cold weather operability is even less clear when dealing with B5 blends or higher. Approximately 62% of the current Canadian heavy truck fleet is of pre-2002 vintage, CTA said.
The other problems associated with a biodiesel mandate is blending and manufacturing standards. Improper blending practices, even with proper quality standards, can lead to problems. The engine manufacturers and petroleum producers have stated that splash blending is not desirable and that in-line blending is superior. Currently, in-line blending facilities are in short supply and adherence with ASTM and BQ 9000 standards is only voluntary in Canada, CTA said.
In addition, the 2010 model year trucks will use a significantly different technology platform compared to existing equipment in order to meet Environment Canada/USEPA smog emission regulations. The new engines were not part of a recent demonstration project conducted in Alberta. "All the demonstration program showed us is that blended properly and manufactured to appropriate standards, biodiesel blends at B2 or less can be operated in Canadian winter conditions by most (but not necessarily all) heavy truck engines up to the 2007 model year," Bradley said. "Only the consumer, in this case the trucking industry, will remain exposed unless the regulatory approach to the mandate addresses our key concerns. Being told by the biodiesel producers that we can sue them if their product is not of sufficient quality to work in our engines is of no solace. The industry does not comprise thousands of small companies who will not have the resources to launch such action, nor should they have to be put in this position."
As a result for its concerns, CTA is calling upon Canada's federal environment minister, Jim Prentice, to re-think the federal government’s approach to the biodiesel mandate and ensure that the regulations include the following:
•The averaging provision in the 2006 Notice of Intent should be removed and it be prescribed that no diesel fuel shall be sold into the general heavy commercial truck marketplace above the B2 level to reduce the risk of operability and durability problems for all heavy trucks and to protect all truck owners’ engine warranties.
•The sale of biodiesel blends higher than B2 should permitted only as a specialty fuel, protecting on-road consumers from its use.
•In time, CTA believes that the majority of engines will be able to operate with certain blends above B2. Consequently, CTA would accept a clause in the regulation that would allow for the level of the biodiesel blend to be increased once a determination has been made that releasing such blends into the general marketplace would not create operability, durability and warranty issues.
•The regulation should include a provision that will require the identification of regions and calendar dates in which biodiesel blends when should not be used due to extreme cold weather.
•ASTM standards and BQ 9000 certification must be regulated to ensure compliance at all times.
•Environment Canada must develop regulatory controls regarding proper blending processes.
•A properly conducted regulatory impact statement must also be conducted to clearly isolate the cots impact of biofuel on the price of on-road diesel fuel. This will be essential for motor carriers to justify the impact of biodiesel on fuel surcharges to their customers.
In addition to the above regulatory requirements, CTA says Environment Canada should establish an office to monitor and analyze problems associated with the biodiesel mandate and to establish a help-line to receive information and provide answers to heavy-duty engine users during the introduction of biodiesel into their fleets and beyond.