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Final Draft
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A ROADMAP FOR REDUCING BLACK
CARBON FROM HEAVY DUTY DIESEL
VEHICLES AND ENGINES IN BANGLADESH
FINAL DRAFT
Dhaka, March 2015
Final Draft
2
Contents
page no.
Contents 02
List of Abbreviation 03
Executive Summary 04
1. Introduction 05
1.1 Rationale for low-sulfur diesel 06
1.2 Purpose of the Roadmap 07
1.3 Methodology for the development of the roadmap 08
2. Technical Aspects of Diesel Combustion and Emission 12
3. Emission Control Technologies for Diesel Engines 13
4. Effects of Fuel Quality on Diesel Emissions 14
5. Diesel Emissions: Bangladesh Scenario 15
6. Cost of Low Sulfur Diesel 20
7. Implications of Introducing Low-Sulfur Diesel (LSD) 20
8. Policy Framework: Roadmap Actions and Milestones 21
8.1 Overcoming economic barriers and creating incentives for LSD
deployment 21
8.2 Addressing non-economic barriers 21
9. Final Draft of the proposed road map 22
10. Milestones for introducing LSD 30
11. Conclusions 33
12. Future Plans 35
Appendix-A: Summary of meetings with focus groups and stakeholders 36
Appendix-B: First draft of the proposed road map 49
Appendix-C: Documents Provided by Stakeholders 53
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LIST OF ABBREVIATIONS
BADC Bangladesh Agricultural
Development Corporation
ECD Emission Control Devices
BPC Bangladesh Petroleum
Corporation
ERL Eastern Refinery Ltd
BR Bangladesh Railway GOB Government of Bangladesh
BRTC Bangladesh Road Transport
Corporation
HC Hydro-Carbon
BSTI Bangladesh Standards and
Testing Institute
HSD High Speed Diesel
BRTA Bangladesh Road Transport
Authority
HSFO High Sulfur Fuel Oil
BIWTA Bangladesh Inland Water
Transport Authority
KPC Kuwait Petroleum
Corporation
BIWTC Bangladesh Inland Water
Transport Corporation
LSD Low Sulfur Diesel
BUET Bangladesh University of
Engineering and Technology
NOx Nitrogen Oxides
CAA Clean Air Asia PDB Power Development Board
CO Carbon Monoxide PM Particulate Matter
CNG Compressed Natural Gas SOx Sulfur Oxides
DPF Diesel Particulate Filter WHO World Health Organization
DOE Department of Environment
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EXECUTIVE SUMMARY
As a developing country, in Bangladesh, the use of motorized vehicles has been increasing at
a faster rate which leads to environmental pollution especially in highly populated
metropolitan areas. One of the most hazardous of these pollutions is the particulate matter.
High sulfur content in diesel is partly responsible for particulate matter which is a major
pollutant from diesel vehicles. More importantly, the emissions from diesel engines make the
emission control devices like diesel oxidation catalyst, diesel particulate filter (DPF), etc.,
inactive when the engine runs with high sulfur diesel.
The Government of Bangladesh (GOB) has taken many initiatives to reduce pollution. In
Bangladesh, Department of Environment (DOE) in collaboration with Clean Air Asia (CAA)
has initiated a project titled Roadmap for Reducing Black Carbon from Heavy Duty Diesel
Vehicles and Engines in Bangladesh to achieve a pollution free environment within a certain
period of time. Department of Mechanical Engineering, Bangladesh University of
Engineering and Technology (BUET) provided the technical consultation to DOE for this
roadmap project.
The proposed roadmap has taken into consideration the views and feedbacks from all relevant
stakeholders through a series of meetings and discussions. This roadmap incorporated
milestones of lowering the sulfur content on imported diesel fuel from the current level of
2500ppm to a stricter level of 500ppm by 2016. Eventually, it is targeted to be as low as
350ppm by 2020 and 50ppm by 2023. The consultation team recognizes the technical,
economic and socio-political implications of pursuing stricter standards. It is also suggested
that proper co-ordination of activities like - standardization of measurement of sulfur content
in diesel, up-gradation of vehicle emission standard for low sulfur diesel and effective control
of fuel adulteration is essential to achieve the full benefit of using low sulfur diesel. The
process should be accompanied by a public awareness program to create a better
understanding regarding the use of low sulfur diesel among the end users. The report
suggested a strategy for Eastern Refinery Ltd (ERL), the only major local producer of fuel in
the country, to be able to cope up with such reduction on sulfur level in their diesel product.
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1. INTRODUCTION
Environmental pollutions including air pollution have been increasing day by day in
Bangladesh. The use of motorized vehicles is increasing at a faster rate which leads to
environment pollution especially in highly populated metropolitan areas. One of the most
hazardous of these pollutions is the particulate matter or PM. High sulfur content in diesel is
partly responsible for particulate matter which is a major pollutant from diesel vehicles.
These emissions from diesel engines make the emission control devices like catalytic
converter, diesel particulate filter (DPF), etc., inactive when the engine runs with high sulfur
diesel.
A pollution free environment is the dream of all and the Government of Bangladesh (GOB)
has taken many initiatives to reduce pollution. In Bangladesh, Department of Environment
(DOE) in collaboration with Clean Air Asia (CAA) has initiated a project titled Roadmap
for Reducing Black Carbon from Heavy Duty Diesel Vehicles and Engines in Bangladesh to
achieve a pollution free environment within a certain period of time. Department of
Mechanical Engineering on behalf of the Bureau of Research, Testing and Consultation of
Bangladesh University of Engineering and Technology (BUET) has become the technical
consultant to DOE for this roadmap project. In this regard, a team of experts consisting of 5
members from the Department of Mechanical Engineering has been working on with an
ultimate goal of proposing a roadmap.
The specific objectives that are being fulfilled by this Consultation team are as follows:
i) Department of Environment will arrange discussion meetings among the stakeholders
and the Consultant will gather the feedback for the proposed roadmap from these
stakeholders. The responsibility to invite the participants from government, private
sectors and civil societies to join the stakeholder groups lies with the DOE.
The stakeholders will express their views on the existing fuel / vehicle emission
standards in Bangladesh and sort out the barrier for implementing that. The possible
barrier for the proposed roadmap will also be highlighted and way out to solve /
overcome the barrier will be discussed. The shortcomings of different
implementing/enforcing authorities will also be considered and the remedy will be
proposed.
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ii) The technical aspects for using high sulfur content diesel in vehicles and engines will
be highlighted by the Consultant to all the stakeholders so that they can contribute to
develop a roadmap for Low Sulfur Diesel (LSD).
iii) The upcoming roadmap will be proposed by the Consultation group and will be
reviewed / modified in the stakeholders forum discussion meeting.
iv) The Consultation team will also provide technical assistance for the up-gradation of
Eastern Refinery Ltd (ERL).
1.1 Rationale for Low-Sulfur Diesel
Pollutants are formed in diesel engines, which are very harmful for both environment and
human health. The major pollutants that are produced during the diesel combustion are
Particulate Matter (PM), Nitrogen Oxides (NOx), Unburnt Hydro-Carbon (HC), Sulfur
Oxides (SOx) and Carbon Monoxide (CO). Particulate matters from diesel engines consist of
primarily carbon particles, the remainders are hydrocarbon compounds (some of which are
bound to soot), and a few are sulfates in the form of aerosols. The adverse effects of pollution
from diesel engines are well known. SO2 is the principal and most ubiquitous urban air
pollutant which is a highly irritating gas, and at levels as low as 0.3 to 1.0 ppm it can be
identified by either smell or taste. The sulfate particulate matter (PM) is very much harmful
for human body especially for small children.
During breathing, small particles of diesel exhaust are drawn into the lungs. The microscopic
particles in diesel exhaust are less than one-fifth the thickness of a human hair and are small
enough to penetrate deep into the lungs, where they contribute to a range of health problems.
Headache, cancer, asthma, cardiovascular diseases, chronic obstructive pulmonary diseases,
diabetes and many other diseases might be caused from diesel pollutants. In 2012, the World
Health Organization (WHO) declared that diesel pollutants are carcinogenic. These pollutants
can also reduce visibility in the environment by creating smog. It may also be responsible for
acid rain.
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To reduce pollutant emissions from diesel engines, a number of methods are available. Two
of the most important ones are to use emission control devices (ECD) and to use good quality
fuel. These two, however, are interlinked in such a way that one requires the use of the other.
Diesel emission control devices, such as, catalytic converters, DPF, etc. become inactive
when they come in contact with oxides of sulfur. Catalysts and other elements inside the
devices are covered by SOx thus losing its capability to convert the harmful gases to more
benign ones. In addition, sulfur compounds in the exhaust envelope PM making it larger
which ultimately clog the DPF.
At present, the upper limit of sulfur content in diesel fuel in Bangladesh is 2500 ppm (0.25%
v/v). However, many stakeholders claim that the actual level at the end-users is much higher.
As a result, recently imported vehicles which are fitted with ECD face a number of technical
problems running with high-speed diesel (HSD). In most such cases, the ECD are removed
from the vehicle thus contributing to pollutant emissions like the older generation vehicles.
The main impact of using low sulfur diesel is on the emission reduction capability of the
post-engine emission control devices like catalytic converter, diesel particulate filter (DPF),
etc., which are incorporated in the exhaust system of modern diesel engines.
1.2 Purpose of the Roadmap
Diesel engine vehicles running in and around Dhaka city contribute to pollutant emissions
into the atmosphere. So reducing sulfur content from the current 2500 ppm down to 500 or
even to 50 ppm will indeed have a considerable effect on the air quality of the Dhaka city. In
this case, some locality in the immediate vicinity of the vehicles (roadside gatherings /
inhabitants) will have some immediate benefits out of this. In the long run, the entire city air
will get the benefits from the reduced sulfur content in diesel engines and vehicles.
Moreover, from technical point of view, 2-3 years down the road, most of the diesel engines
and vehicles will have ECD and demand low sulfur diesel for their proactive operation. In
that case, if we do not take necessary steps now to gradually reduce the sulfur content of
diesel, then the new diesel vehicles will face major challenges running on roads. To avoid
such situation, reduction in sulfur content in diesel is necessary.
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With a view to reducing high sulfur content in diesel, a roadmap with relevant guidelines
have been proposed here by considering the views expressed and data collected from
different stakeholders during focus group meetings (FGMs) and keeping in mind the socio-
economic condition of the country.
1.3 Methodology for the development of the Roadmap
In order to formulate a draft roadmap for developing low sulfur diesel and clean vehicle
emissions policies in Bangladesh, the following activities have been carried out by the
Consultant (BUET):
(a) Organization of bi-monthly stakeholder meetings in Bangladesh to provide forum for
stakeholder consultation. DOE invited participants from the government, private
sectors and civil societies to join the national stakeholders meetings. The stakeholder
groups were invited so as to:
i. Discuss and package the benefits of low sulfur diesel and clean vehicle
emissions for Bangladesh.
ii. Conduct a thorough review of existing national regulations, emission
standards, barriers for implementing the previous roadmap for clean fuels and
vehicles, incentives that might promote low sulfur fuel and clean vehicle
emissions in Bangladesh, assist funding for setting up desulfurization unit in
Eastern Refinery Limited.
iii. In addition to the national stakeholders meetings, the Consultants had 5 (five)
Focus group discussion (FGD) meetings that are listed in Table 1.
(b) In the stakeholders meetings, the participants were given a set of questions relevant to
their interests. The Consultants recorded their comments during these meetings. The
summary of these meetings are reported in Appendix-A.
(c) Evaluation of the benefits of low sulfur fuel and clean vehicle emissions standards for
Bangladesh.
(d) Review of the existing Bangladesh national regulations and incentives that would
promote low sulfur fuel and cleaner vehicle emissions in Bangladesh e.g., on
emission, inspection of fuels and vehicles, catalytic converters, taxation regimes etc.
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Table 1: Stakeholders Participating in the Focus Group Discussion Meetings (FGDs):
Activities/Meeting Time / Date Participants
All Stakeholders Meeting-1 May 28, 2013 All Stakeholders
All Stakeholders Meeting-2 July 29, 2013 All Stakeholders
Focus Group Meeting-1
(in Chittagong)
August 04,
2013
ERL, BPC and all other oil distribution
companies of the country.
Focus Group Meeting -2 October 23,
2013
End-user stakeholders , i.e., Vehicle Owners
Association, Vehicle Traders Association ,
Vehicle Importers Association, etc.
Focus Group Meeting -3 January 15,
2014
BRTA, BSTI, DOE, Traffic Authority,
Dhaka Development Authority, etc.
Focus Group Meeting -4 February 25,
2014
Fuel Pump Owners' Association, DOE,
Generator Importers' Association, Private
Sector Power Plant Companies, etc.
Mid-Term Report
Presentation
09 April, 2014
DoE, Clean Air Asia (CAA), Vehicle
Importer Association, Communication
Ministry, BSTI, Ministry of Energy and
Mineral Resources, Science Laboratory and
Bus-Truck Owner Association.
Focus Group Meeting-5 25 June, 2014
DoE, BADC, BSTI, BRTC, ERL,
Communication Ministry, Ministry of
Energy and Mineral Resources.
2nd National Stakeholder
Meeting
29 October,
2014
DoE, BADC, BSTI, ERL, Ministry of
Energy and Mineral Resources, Truck
Owners' Association and Petrol Pump
Owners' Association
3rd (Final) National
Stakeholder Meeting
14 January
2015
DoE, Clean Air Asia, BRTA, BSTI, BPC,
ERL, Ministry of Energy and Mineral
Resources, Ministry of Industries,
Bangladesh Railway, BCSIR , Vehicle
Importers' Association.
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Analysis of Feedback from FGDs and Stakeholders Meetings:
From the deliberations with the stakeholders, the consultant team (BUET) was informed
that of the total demand of diesel in the country, about 15% is produced by the ERL
which is about 0.4 million tons per year and the rest 85% is imported from abroad. From
the trend analysis of the given data the same was found to be true.
The ppm content of sulfur in diesel produced by the ERL is around 5000 ppm and the
ppm content of the imported diesel is around 2000 ppm. Thus when these two are
blended, the resultant blend is around 2500 ppm. Since the ERL's diesel contains very
high sulfur content, so even importing diesel with zero ppm sulfur cannot produce a
blend of less than 500 ppm sulfur if the ERL production (15%) and import (85%)
percentage remains the same. So blending is impractical in case of the necessity of
reducing the sulfur content below a certain level. Table-2 summarizes the situation.
It was also revealed that ERL proposed a capacity expansion of further 3.0 million tons of
crude oil in addition to the existing 1.5 million tons. That would increase the production
of diesel up to 1.2 million tons. Keeping in mind that the demand for diesel has been
increasing at the rate of about 0.1 million tons per year especially in the transport sector,
by the time that the project is materialized, the share of ERL in the diesel market will be
somewhere between 30 and 40 percent. ERL also proposed a 1.4 million ton
desulfurization unit which will be able to produce 350 ppm sulfur diesel. This level does
not seem to be a prudent one. Such a plant should have an economic life of at least 25
years. It is quite likely that within about 10 to 15 years time, most of the other countries
will set the sulfur content at 10 ppm at most (developed countries have already set the
standard at 10 ppm and advancing towards 0 ppm in the very near future). Therefore,
ERL should revise their proposal to set the sulfur level to 0 ppm or 10 ppm at most for
their proposed desulfurization plant.
The additional costs that will be incurred in case of import of 500 ppm sulfur diesel
instead of 2000 ppm sulfur diesel is substantially low. Considering the huge benefits that
will be gained in the form of clean atmosphere, reduced health cost, increased vehicle life
and others, this additional cost seems quite reasonable.
So instead of distributing it to the transportation sector, all the diesel produced by the
ERL should be channeled to limited sectors such as remote power plants, marine vehicles,
industries, etc. which are far from the cities. For the transport sector, 100% directly
imported diesel of the required amount (500/350/50 ppm) sulfur content according to the
proposed roadmap should be distributed.
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Some of the nations such as China and India setup a split standard for their metros (with
lower allowable ppm level) and other regions (with higher allowable ppm level). From
the discussion with the stakeholders, it was revealed that two separate standards are not
feasible for a small country like Bangladesh. There are cross-country travels and logistic
and administrative shortcomings related to the marketing, distribution, and storage of
fuels of two different standards.
On the other hand, from the deliberations with the stakeholders, it was observed that all
these efforts for reducing sulfur in fuel will not be fruitful unless we can control
adulteration of diesel fuel. Such adulterations were reported to have been taking place at
various stages such as during lighterage from marine vessels, at the storage depot, tank
lorries and at various distribution channels. In such cases, post-engine emission control
devices cannot be operated effectively and people will be deprived of clean air despite
buying expensive vehicles as well as fuels. So, some definitive measures must be taken to
control these adulteration processes. Continuous monitoring of the various processes and
channels by the concerned authorities, law enforcements through exemplary punishments,
introduction of anti-adulteration technical measures, and measurement of fuel properties
to indicate the extent of adulteration are the few steps that can be implemented to control
adulteration.
It was felt mandatory to set a standard methodology to measure sulfur content and other
fuel properties so that no controversy arises from the measurement process. At present,
there is a lack of coordination between the concerned parties like ERL, BSTI, and DoE,
regarding such methodologies. Experiences and technologies from the neighboring and/or
developed countries can be adopted to set up such measuring and monitoring
stations/authorities.
Effect of emission from HSFO-run power plants and coal-based brick-fields situated in
and around Dhaka city may have a significant role on the resulting sulfur content in the
air. However, the team does not have enough data to quantitatively assess their
contribution of sulfur pollution in the air of Dhaka city. If their sulfur pollution is at a
significant level this may outweigh the benefits of using low sulfur diesel in vehicles.
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2. TECHNICAL ASPECTS OF DIESEL COMBUSTION AND EMISSION
The particles from diesel engines consist of hydrocarbon particles, the remainders are
hydrocarbon compounds (some of which are bound to soot), and a few are sulfates in the
form of aerosols. The creation of soot is largely determined by the local temperature (800
1400 K) and the oxygen concentration, and occurs in two phases. The reactions in the
primary formation phase occur almost exclusively from radical chain mechanisms in the core
of the fuel jet behind the jet tips O, H, and OH radicals are formed. Cyclic and polycyclic
aromatic hydrocarbons (PAH) form by polymerization and cyclization. Uncombusted and
partially combusted hydrocarbons, especially aldehydes can bond to the secondary particles
due to their large specific surface. As combustion proceeds, the secondary formation phase is
soot reoxidation that is governed by the dwell time and oxygen concentration. The diameter
of the particles varies between 1 and 1000 nm. For homogeneous mixtures, soot is found in
the exhaust emissions when the mixture is very rich (50% of theoretical air); at more than
60% air under optimum conditions, there is no demonstrable soot formation. Important
unrestricted components in untreated exhaust from diesel engines are cyanide, ammonia
(NH3), sulfur dioxide (SO2), and sulfates. Specifically, hydrocarbons, methane, ethane,
ethene, ethine, benzene, and toluene are of particular interest.
The adverse effects of pollution from diesel engines are well known. SO2 is the principal and
most ubiquitous urban air pollutant which is a highly irritating gas, and at levels as low as 0.3
to 1.0 ppm it can be identified by either smell or taste. Because of its marked solubility in
water, it is almost 100 percent absorbed in the upper airways in human beings. Even a mild
exposure (6 to 12 ppm) can cause serious respiratory and related troubles. Similar
phenomenon can result from chronic irritation by other pollutants such as NO2 and O3. An
intense exposure to SO2 may lead to laryngeal spasm or pulmonary edema, both of which
conditions could be fatal. Sulfate ions in different substances vary widely in their irritant
potency. The sulfate ion itself is not an irritant. The most potent agent is sulfuric acid
(H2SO4), followed by ferric sulfate, zinc sulfate, and ammonium sulfate.
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3. EMISSION CONTROL TECHNOLOGIES FOR DIESEL ENGINES
Pollution from diesel engines can be controlled in different ways; some are performed before
the combustion of diesel and some after the diesel combustion. The devices which are
employed before combustion is called pre-ignition devices and devices that are used after the
combustion is called post-ignition devices.
Pre-ignition devices: Hot air-intake system and improved fuel metering electronic
governor.
In-Engine systems: (i) Direct and indirect fuel injection, injection retardation (ii) Valve
design - Vtech, 16 Valve, DOHC (iii) EGR: Exhaust Gas Recirculation and (iv) Stratified
charge combustion, lean burn
Post-ignition devices:
(i) Diesel Particulate Filter (DPF): Diesel particulate filters (DPF) reduce diesel PM
emissions through filtration. This technology is very efficient in controlling diesel PM
emissions, and has been demonstrated to reduce diesel PM by over 90 percent.
(ii) Diesel Oxidation Catalyst (DOC): Diesel oxidation catalyst (DOC) reduces the emissions
of particulate matter (PM), carbon monoxide (CO) and gaseous reactive organic gas
(ROG) from diesel engines by catalytic oxidation.
(iii) Continuously Regenerative Trap (CRT): The CRT system utilizes a ceramic wall-flow
filter to trap particulates. The trapped particulate matter is continuously oxidized by
nitrogen dioxide generated in an oxidation catalyst which is placed upstream of the filter.
The CRT requires ultra low sulfur fuel and a certain minimum NOx/PM ratio for proper
operation.
(iv) Selective Catalytic Reduction (SCR): Selective Catalytic Reduction (SCR) is an
advanced active emissions control technology system that injects a liquid-reductant agent
through a special catalyst into the exhaust stream of a diesel engine. The reductant source
is usually automotive-grade urea, otherwise known as Diesel Exhaust Fluid (DEF). The
DEF sets off a chemical reaction that converts nitrogen oxides into nitrogen, water and
tiny amounts of carbon dioxide (CO2), natural components of the air we breathe, which is
then expelled through the vehicle tailpipe.
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4. EFFECTS OF FUEL QUALITY ON DIESEL EMISSIONS
The minimum requirements for diesel fuel are primarily concern density, ignition quality
(cetane number), boiling curve, resistance to cold, and sulfur content. Petroleum naturally
contains sulfur depending on where it comes from. The sulfur is chemically bound, and more
than 95% is converted into gaseous sulfur dioxide upon combustion the remainder largely
passes into the particle mass of the exhaust that contains sulfurous acids and sulfates leading
to corrosion and exhaust pollution. In addition to the soot in diesel exhaust that is suspected
of being carcinogenic, there are also polycyclic aromatic hydrocarbons (PAH). Local rich
conditions during combustion lead (via the intermediate steps of acetyls and polycyclic
hydrocarbons) to the formation of graphite-like soot particles. By means of coagulation and
agglomeration processes, soot particles approximately 100 to 300 nm in diameter (median)
arise from these approximately 110 nm (1 nm = 10-9 m) primary particles. Since the large
surface area (up to 200 m2/g) of these particles make them strongly adsorbent, a large share
(greater than 50% by weight) of hydrocarbons, sulfates, water, and lubricating oil
components can be demonstrated in diesel soot in addition to carbon. One known method for
reducing the total emission levels of particulate matter (TPM) from diesel engines is to use
low-sulfur (0.05 percent by weight, equivalent to 500 ppm) diesel fuel. The stringency of
legal restrictions on fuel sulfur has rapidly been tightened in recent years and continues to
tighten still (although, from one country to another, there may be field issues for some time).
The main reason for enforcing the use of low-sulfur diesel is that sulfur causes havoc in
emission control systems.
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7%4%
33%55%
1%
Sector-wise Consumption of HSD during 2012-13
1
2
3
4
5
Power
Agriculture
Domestic and others
IndustryCommunication
5. DIESEL EMISSIONS: BANGLADESH SCENARIO
Bangladesh is an oil-importing country. The only refinery in the country is the Eastern
Refinery Limited (ERL) located in Chittagong. It has a capacity to handle 1.5 million tons of
crude oil per year. The major petroleum products are high-speed diesel (HSD) and high-
sulfur fuel oil (HSFO), constituting more than three-fourths of their production. The sulfur
content in HSD and HSFO are 0.5% (5000 ppm) and 3.5% (35,000 ppm) respectively.
However, the volume of HSD produced in ERL is relatively small and can meet only about
15 percent of the total national diesel demand of the country. In order to meet this
requirement, the controlling agency of ERL, Bangladesh Petroleum Corporation (BPC)
imports the remaining 85 percent through ERL from different countries. A FGM with BPC
and ERL revealed that the finished product, viz., HSD is important from Kuwait Petroleum
Corporation (KPC) which has a sulphur content of about 2000 ppm. HSD imported from
other sources have sulfur content of 2500 ppm. The current practice of ERL is to blend the
imported HSD from KPC with their own product to deliver HSD for country-wide
consumption with sulfur content of 2500 ppm.
The current emission regulations regarding diesel vehicles allow import of vehicles
complying EURO2 standard (for Dhaka and Chittagong) and EURO1 standard (for the rest of
the country) and the free acceleration smoke density limit is 40 HSU (k = 1.2 m-1) for
naturally aspirated and 61 HSU (k = 2.2 m-1) for turbo-charged diesel engines.
The data related to the production, consumption and import are gathered from various sources
and are presented in the following figures and tables.
Fig. 1: Sector-wise consumption of HSD in Bangladesh (2012-13)
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0
200000
400000
600000
800000
1000000
1200000
1400000
1600000
1800000
2008-09 2009-10 2010-11 2011-12 2012-13
Co
ns
um
pti
on
(M
T)
Years
Sector-wise Consumption of HSD during Last 05 Years
Power Industry Agriculture Communication Domestic and Others
0
200000
400000
600000
800000
1000000
1200000
2003-04 2004-05 2005-06 2006-07 2007-08 2008-09 2009-10 2010-11 2011-12 2012-13
Sale
s in
MT
Years
Actual Sales of Fuel Oil Handling System (FOHS) during Last 10 Years
Fig. 2: Consumption (sector-wise) of HSD (last 5 years)
Fig. 3: Actual sales of High Sulfur Fuel Oil (last 10 years)
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0
500000
1000000
1500000
2000000
2500000
3000000
3500000
2003-04 2004-05 2005-06 2006-07 2007-08 2008-09 2009-10 2010-11 2011-12 2012-13
Sale
s in
MT
Years
Actual Sales of High Speed Diesel (HSD) during Last 10 Years
0
500000
1000000
1500000
2000000
2500000
3000000
3500000
1 1. 5 2 2. 5 3 3. 5 4 4. 5 5
MT
Year
HSD Production by ERL, Consumption and Import
Production by ERL
Total Consumption
Import
2008-09 2009-10 2010-11 2011-12 2012-13
89.3% of consumption
85.6%
88.4% 88.5%
87.1%
Fig. 4: Actual Sales of High Speed Diesel (HSD) (last 10 years)
Fig. 5: HSD production and import by ERL (total consumption)
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A hypothetical analysis was done with the resulting sulfur content in diesel if the imported
diesel is blended with that produced by ERL, as shown in Table 2.
Table 2: Sulfur ppm after blending of imported and ERL produced HSD
Sulfur ppm in ERL produced
HSD (ERL production is about
15% of country demand)
Sulfur ppm in imported HSD (import is
about 85% of country demand)
Sulfur ppm
after
blending
5000 2000 (from KPC) [at present] 2450
5000 2500 (from other source) [at present] 2875
5000 500 [in future] 1175
5000 50 [in future] 793
5000 0 [assumption] 750
Table 2 clearly indicates that at present, ERL can deliver HSD with 2450 ppm sulfur
after blending (which is less than 2500 ppm, the country standard) only from the imported
HSD of KPC (which has about 2000 ppm of sulfur). In case of import from other sources
(2500 ppm), after blending, it does not meet the present standard. It also indicates that
importing HSD with 0 ppm sulfur and after blending with 5000 ppm of ERL produced HSD,
the value of sulfur ppm below 750 cannot be achieved.
Therefore, if the road map is set for 500 ppm in the near future, the blending of imported
HSD with that produced by ERL will not be compatible with the roadmap. In such cases,
HSD produced by ERL can have restricted uses in power plants in remote areas, marine
transports, or country-side irrigation, while the imported low sulfur diesel (LSD) can be used
in urban transports and other uses. In order to increase their share in the HSD market, ERL
proposed for a second Crude Processing Unit with an installed capacity of 3.0 million tons
per year along with a desulfurization plant (350 ppm) of a capacity of 1.4 million tons. That
means that had the proposed plant come into existence, ERL will be able to produce about 1.9
million tons of HSD against the present demand of around 3.0 million tons.
However, it is highly likely that by the time the proposed project is completed, the demand
for HSD will increase to about 3.7 million tons. That is, the country will need to import more
than half the total demand.
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In the discussion meetings, many stakeholders voiced their concern about the adulteration of
fuel (including diesel) in different stages of handling (from port up to the end user i.e., the
vehicle users). They believe that there is a widespread adulteration of fuels and they finally
recommended that all the concerned authorities should be accountable. They emphasized that
without proper control of adulteration at field level, all the efforts for reducing pollution by
improvement of fuel quality may prove fruitless.
Sulfur (from HSD) Scenario in Bangladesh and around Dhaka City
In the whole country:
Sulfur content in HSD in Bangladesh is about 2500 ppm. The total consumption of HSD in
2012-13 year in Bangladesh in power, industry, communication, domestic and other sectors is
29,64,604 MT which produced 7,412 MT of sulfur or sulfur compounds in Bangladesh from
HSD.
In and around Dhaka City:
In 2012-13, the consumption of HSD in Bangladesh in the whole communication sector was
16,21,675 MT.
Considering 90% of the diesel vehicles was used in 4 major cities (Dhaka, Chittagong,
Khulna and Rajshahi) and 50 % of which can be assumed to be running in Dhaka region only.
Again assuming 40% of the diesel vehicles of Dhaka region were used in and around Dhaka
city at a time, they produced sulfur amounting to about 730 MT in 2012-13 in and around
Dhaka city.
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6. COST OF LOW SULFUR DIESEL
Cost of diesel fuel includes among others, the price of crude oil, costs of refining,
distribution, marketing and taxes. In the US market, the price of crude oil and refining
constitute about 70% of the total cost. The pump price of ultra-low sulfur diesel (ULSD)) (0-
15 ppm sulfur) is about US$ 1 per litre (*Source: www.eia.gov) over the last four years or so.
It is interesting to note that the cost of producing diesel is generally higher than that of
gasoline.
In Bangladesh, until recently the cost of diesel production was higher than the pump price.
But, the Government of Bangladesh, since inception, had been subsidizing the price of diesel
to facilitate the various economic sectors, especially, the farmers and in general, the
population. While the price of fuel in many developed countries are driven by market forces,
that in Bangladesh and some other countries are fixed by the Government.
The authors are unaware about any detailed study on the cost of LSD in Bangladesh market.
Verbal communications in one of the FGDs, it was revealed that the pump price of diesel
may go up by about Tk. 4 to Tk. 5 per liter. This may increase the cost associated with diesel
import in the order of taka 1500 crore per year. Thus, before commenting on the price of
ULSD, a proper study on the production and marketing costs needs to be accomplished.
7. IMPLICATIONS OF INTRODUCING LOW-SULFUR DIESEL (LSD)
The implications of introducing LSD in Bangladesh are many. A few of the important ones
are namely, technical, economic, and political. Technical advantages and disadvantages of
introducing LSD in Bangladesh with larger population of older vehicles in the diesel-driven
fleet have already been discussed in sufficient details in earlier sections. Economic
implications are wide ranging. From the past experiences, one can easily conclude that there
is a direct correlation of prices of essentials and other commodities and services with the
price of fuel. If the latter increases, all other prices go up almost immediately before the
market stabilizes.
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Political implications are tied up with the economic ones. Any increase in the price of fuels
causes an uproar in political arena. However, if adequate and effective measures are taken by
the various functionaries of the Government to make people aware of the bad effects of high-
sulfur diesel on human health and environment as well as the benefits of using LSD are
highlighted, the dissenting voices would not be too vocal.
8. POLICY FRAMEWORK: ROADMAP ACTIONS AND MILESTONES
8.1 Overcoming Economic Barriers and Creating Incentives for LSD Deployment
As discussed in the previous section, the immediate effect of rise in fuel prices is that the
transport costs of all forms go up. This in effect put an adverse effect on the economy as a
whole. Two propositions can be thought of in this regard. Firstly, the Government, for the
sake of betterment of the environment, can continue giving subsidies for the first three years
which would be decreased gradually over this period. This would help ease the burden on the
people. Secondly, the Government can take up an aggressive public awareness program to
drum up the good effects of using LSD in regard to health and environment for the period
from now up to the deployment of LSD; i.e., in the period put forward in the proposed
roadmap. Then the stakeholders can prepare themselves for the increase in LSD price well in
advance.
Other incentives like reduced taxation for using LSD and importing of LSD vehicles,
imposing higher tax and duties for higher emission vehicles, etc., may also be implemented.
8.2 Addressing Non-Economic Barriers
Non-economic constraints are generally more difficult to handle than economic barriers. The
leaders of the country have to be proactive to motivate people in such a manner so that the
majority may feel that the introduction of LSD is necessary. A similar model of replacing
two-stroke three-wheelers in Dhaka and Chittagong with less polluting CNG driven three-
wheelers may be put to use.
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9. FINAL DRAFT OF THE PROPOSED ROADMAP
The first draft of the proposed roadmap was placed in a meeting with all the major
stakeholders, for their feedback. The draft had two options in the proposed roadmap,
which were discussed in detail (as included in Appendix-B). From the discussions with
stakeholders a number of interesting features and new findings were revealed
The process of importing low sulfur diesel would require some lead time for
acquiring diesel purchase from international suppliers. Refineries which typically
supply diesel to Bangladesh are having their up-gradations to produce low sulfur
diesel as well. Ministry of Energy and Mineral Resources, BPC and ERL are the
major stakeholders in this process.
The standardization of the procedure for measurement of sulfur content in diesel is
not completed yet in Bangladesh. The process also needed further acceptable
coordination among relevant government agencies. DoE, BSTI, ERL and BPC are
the major stakeholders in this process.
The modernization and establishment of desulphurization plant in ERL will require
a minimum lead time of three years before it could come into operation. Such
process may start in 2015 and currently targeted for achieving 350 ppm level. 350
ppm appears to be a low level of requirement based on the fact that 50 ppm diesel
will be standard within the life time of such renovations of ERL. Provision of
further improvement of low sulfur diesel must be included in the renovation plan of
ERL. Ministry of Energy and Mineral Resources, Ministry of Finance and ERL are
the major stakeholders in this process.
The production of diesel from ERL could not be stopped as it also produces HSFO,
octane, petrol, kerosene and a number of other products which are used as raw
materials in different industries. Possible internal markets where ERL diesel could
be separately channeled without blending with imported diesel were explored. At
first agriculture, power generation, inland water transport and railway have been
considered. Feedback from concerned stakeholders revealed a number of
limitations in this regard.
(i). Irrigation in agriculture uses sufficient amount (33%, i. e., more than a million
ton per year) of diesel and the existing engines can use diesel with higher
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23
sulfur content, but there is no separate distribution channel for such diesel.
Farmers use the same diesel as transportation and receive some financial subsidies
from the government. The demand for diesel varies seasonally and introducing a
cheaper diesel could also increase the possibility of widespread fuel adulteration.
This did not appear to be a prospective sector.
(ii). Power plants using diesel fuel could be a viable option of using ERL diesel.
Diesel used in this sector is about 7% of the national demand which is more than
0.22 million tons per year. However, most of the diesel power plants are owned by
private sectors and they already have their agreement of fuel import/supply in
practice, in which case they may not be interested of changing. This appears to be
a good prospective sector.
(iii). Railway uses small amount of diesel only, reaching about 31,000 tons per year.
With is own distribution network, this appears to be a good prospective sector.
(iv). Inland water transports use a significant part of diesel used in transportation
sector. A large portion of water transport is owned by private vessel owners who
purchase diesel from the same market as road transportation. The portion of diesel
used by vessels owned by government agencies like BIWTC, BIWTA etc.
amounts to a small fraction of only about 13,000 tons per year. This appears to be
a prospective sector.
Table 3 shows a possible list of restricted clients which may be selected for marketing the
diesel produced by ERL. (Estimations are based on the trend of the last 5 years.)
Table 3: Proposed list of consumers for diesel produced by ERL
ERL diesel production
tons per year Restricted clients
Clients expected demand tons per year
350,000 400,000
Diesel Power Plants 2,50,000 300,000
Bangladesh Railway 30,000 40,000
Inland water Transport (Govt
Sector) 15,000 20,000
Inland water Transport /
Industry
(Private Sectors, around ERL)
50,000
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The control of fuel adulteration is essential for getting the real environmental benefit
of using low sulfur diesel and modern diesel engines fitted with post-ignition emission
control devices, both of which involve additional costs. Mixing of fluids like
condensates, used hydrocarbon chemicals and water were reported to adulterate diesel
fuel. Presence of such materials would significantly affect engine emissions and
outweigh the benefit of using low sulfur diesel. These practices have been going on
for a long period of time and involve a number of levels in the distribution channel in
Bangladesh. Taking sufficient measures for the monitoring, implementing law
enforcements and ensuring good coordination of relevant government agencies are
essential to control this problem. Ministry of Energy and Mineral Resources, Ministry
of Home Affairs, BPC and ERL are the major stakeholders in this process.
The emission regulation for diesel vehicles and engines should be updated in
conjunction with the availability of low sulfur fuel. As fuel below 500 ppm level
becomes available in the local market, importing new vehicles and engines only with
diesel emission control technologies must be made mandatory. It may take few years
for the changeover of the fleet to better technology, but since old engines can run on
low sulfur diesel there is no need to maintain a separate supply line for existing
vehicles and engines. In metropolitan cities, the use of CNG in public transport sector
may continue and in case of new diesel vehicles, use of low sulfur diesel and vehicles
fitted with post-ignition emission control devices must be made mandatory. DoE,
Ministry of Commerce and BRTA are the major stakeholders in this process.
The feedback from stakeholders and analyses of the information reveal that a number of
activities need to be synchronized to achieve a realistic and fruitful roadmap for sulfur
reduction in diesel fuel. Solving the problems associated with the high sulfur diesel
currently produced at ERL needs a multiple strategy plan to be implemented. Reducing
sulfur in diesel will definitely involve more cost, but this needs to be weighed against
health benefits and longer engine life. A gradual change is more pragmatic based on the
socio-economic and technical scenario of Bangladesh, but the whole process can not wait
indefinitely for preparation of all the components. Based on the features stated above, the
proposed roadmap for developing low sulfur diesel fuel and clean vehicle emissions
policies in Bangladesh is framed as follows:
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Up to year 2015
Up to year 2015, the policy of importing diesel with 2500 ppm or less sulfur content
may continue. Meanwhile, the diesel produced by ERL will continue to be blended
with the imported one to keep the sulfur content within the current 2500 ppm level.
During this period details of three policies should be finalized in parallel. These
include -
(i) Standardization of sulfur content measurement of diesel fuel
(ii) Up gradation of emission control regulations for diesel vehicles/engines
(iii) Implementation of preventative measures against fuel adulteration
Preparative measures shall be taken to import diesel with 500 ppm sulfur content from
the year 2016.
ERL should also plan and start its modernization process to provide diesel with lower
sulfur content.
Policy regulations for marketing of ERL diesel to restricted customers like diesel
power plants, railway and inland water transport can be included in this range.
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PROPOSED ROADMAP FOR SULFUR REDUCTION IN DIESEL FUEL
*revision recommended **revision mandatory
Sulfur Content
(PPM)
[All over Bangladesh]
Timeline (Years)
2014 2015 2016* 2017 2018 2019** 2020 2021 2022** 2023 2024 2025*
2500 2500 500 500 500 500 350 350 350 50 50 50
Standardization of Sulfur Content
of Diesel X X
Regulation regarding
Emission Control in Vehicles
X X
Control of Fuel Adulteration
X X
Monitoring of Fuel
Adulteration X X X X X X X X X X X X
Awareness Program for
using LSD X X X X X X X X
Imported Diesel
(PPM)
2500 or
less
2500 or
less
500 or
less
500 or
less
500 or
less
500 or
less
350 or
less
350 or
less
350 or
less
50 or
less
50 or
less
50 or less
ERL Diesel
(PPM)
5000 or
less
5000 or
less
5000 or
less
5000 or
less
5000 or
less
5000 or
less
350 or
less
350 or
less
350 or
less
50 or
less
50 or
less
50 or less
Blending of Import and ERL
Diesel X X X X X X X X
Restricted Marketing of ERL
Diesel X X X X
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From the year 2016 till 2019
From the year 2016, import of diesel with 500 ppm or less sulfur content will only be
allowed. The imported fuel will go through the distribution network without blending.
ERL will start its renovation/expansion program for producing diesel with lower
sulfur content. At present, this is planned to take about three years, reaching a sulfur
content of 350 ppm.
Blending of diesel produced by ERL with the imported fuel will not be allowed
during this period. ERL will market its production of high sulfur diesel to restricted
customers only, which may include diesel run power plants, railway and inland
water vessels etc.
All the new diesel vehicles will be mandatory to satisfy the emission regulations,
which generally would require post-engine emission control devices like DPF and
DOC, catalytic converters, etc.
Old vehicles and engines will continue to operate using diesel with sulfur content of
500 ppm.
From the year 2020 till 2022
From the year 2020, import of diesel with 350 ppm or less sulfur content will only be
allowed. This is restricted due to the current plan of ERL to produce 350 ppm diesel.
In case the ERL diesel has lower ppm, the sulfur content of imported fuel can also be
reduced accordingly.
Since the sulfur content of both imported and ERL diesel are of the same order they
could be used separately or after blending.
ERL will continue to improve its process facilities in order to produce diesel with
sulfur content of 50 ppm or less.
For all new diesel vehicles it will be mandatory to satisfy the emission regulations,
which generally would require post-engine emission control devices like DPF,
catalytic converter, and DOC. The proportion of the newer vehicles and engines is
expected to increase significantly in the whole fleet.
From the year 2023 till 2025
From the year 2023, import of diesel with 50 ppm or less sulfur content will only be
allowed.
Since the sulfur content of both imported and ERL diesel will be of the same order,
they could be used separately or after blending.
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If we superimpose the proposed roadmap in the following figure from the Clean Air Asia
(CAA), "Current and Proposed Sulfur levels in Diesel in Asia, EU and USA", it can be
observed that most developed nations such as the EU, Japan and the USA, have already setup
and implemented a sulfur level of 10 to 15 ppm back in 2007-2008. Most other nations are
implementing a sulfur level of 50 ppm including our Asian neighbors, such as, India, China
and Sri Lanka. China and India setup a split standard for their metros (with lower ppm) and
other regions (with higher ppm). So, it can be concluded that reduction in sulfur is a necessity
for us to remain compatible with the global community. But the roadmap to that reduction
could be in line with our techno-economic feasibility. For example, right now a reduction of
sulfur level to 50 ppm or 10 ppm would be a very drastic measure for Bangladesh. Also the
split standards are not recommended for a small country like Bangladesh with small
jurisdiction, cross-country traffic movement and complicated administration.
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Proposed Roadmap of Bangladesh Presented with the Existing Roadmaps of Other Countries
[Source: CAI-Asia. 2010. Current and Proposed Sulfur levels in Diesel in Asia, EU and USA]
Notes: a - under consideration/ discussion; uncertain; b = nationwide supply of 50 ppm commenced in 2003 and for 10 ppm in 2005 due to voluntary goals set by the oil industry; c = marketed;
d = mandatory; e = voluntary standard of 500 ppm, however formal standard remains 2000 ppm, product in the market nationwide varies 500-1000 ppm; f = various fuel quality available;
g = Beijing, Guangdong, Shanghai
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10. MILESTONES FOR INTRODUCING LSD
The following are prominent milestones for the proposed roadmap to make it successful.
Table below shows the major stakeholders associated with milestone events in Bangladesh
with the suggested "Lead Organization" shown in Bold letters.
Table 4: Milestones for introducing LSD in Bangladesh
Event
Sequence Milestones
Stakeholder / Agency
Associated
Recommended
Time Line for
Implementation
1 Finalization of roadmap for low
sulfur diesel DoE 2014-15
2a
Standardization of sulfur content
measurement in diesel as per the
proposed roadmap
BSTI, ERL, BPC, DoE 2015
2b
Up-gradation of relevant
standards (Fuel, Vehicle
Emission)
BSTI, ERL, BPC, DoE 2015
2c Up gradation of regulation of
emission from diesel vehicles
DoE, BRTA,
Ministry of Commerce,
Vehicle Importers/
Vehicle Assembles
2015
2d Control of fuel adulteration BPC, ERL, Home
Ministry, Police 2015
3a Economic analysis of using LSD
DoE, Ministry of Power,
Energy & Mineral
Resources, BPC,
Ministry of Finance
Ministry of
Communication, BRTA
2015
3b
Arrangement of a pilot project to
run Bangladeshi vehicle fleet with
LSD
DoE, ERL, BRTA 2015
3c
Arrangements for import of diesel
with 500 ppm or less sulfur
content
Ministry of Power,
Energy & Mineral
Resources, BPC,
Ministry of Finance
2015
3d Awareness program for the end
users regarding use of LSD DoE, ERL, BRTA 2015-2022
3e Planning for restricted marketing
of ERL diesel from 2016
ERL, Ministry of
Power, Energy &
Mineral Resources,
BPC, PDB, BR,
BIWTC, BIWTA, Local
Industry
2015
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Event
Sequence Milestones
Stakeholder / Agency
Associated
Recommended
Time Line for
Implementation
4**
ERL up gradation / renovation for
producing sulfur content of diesel
to 350 ppm or less
ERL, Ministry of
Finance, BPC, Donor
Agencies
2015-2018
5 Monitoring of fuel adulteration
control measures
BPC, ERL, Home
Ministry, Police 2016-2025
6a Import of diesel with 500 ppm or
less sulfur content
Ministry of Power,
Energy & Mineral
Resources, BPC,
Ministry of Finance
2016
6b Marketing of ERL diesel to
restricted customers
ERL, Ministry of
Power, Energy &
Mineral Resources,
BPC, PDB, BR,
BIWTC, BIWTA, Local
Industry
2016-2019
7a
Up-gradation of relevant
standards (Fuel, Vehicle
Emission)
BSTI, ERL, BPC, DoE 2019
7b
Arrangements for import of diesel
with sulfur content of 350 ppm or
less
Ministry of Power,
Energy & Mineral
Resources, BPC,
Ministry of Finance
2019
7c
Production of diesel from ERL
with sulfur content of 350 ppm or
less
ERL, BPC 2019
7d Review of Road map for 350 ppm
LSD DoE, All Stakeholders 2019
8 Import of diesel with 350 ppm or
less sulfur content
Ministry of Power,
Energy & Mineral
Resources, BPC,
Ministry of Finance
2020
9**
ERL up gradation / renovation for
improving sulfur content of diesel
to 50 ppm or less
ERL, Ministry of
Finance, BPC, Donor
Agencies
2020-2022
10a Review of Road map for 50 ppm
LSD DoE, All Stakeholders 2022
10b
Up-gradation of relevant
standards (Fuel, Vehicle
Emission)
BSTI, ERL, BPC, DoE 2022
10c
Arrangements for import of diesel
with sulfur content of 50 ppm or
less
Ministry of Power,
Energy & Mineral
Resources, BPC,
Ministry of Finance
2022
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32
Event
Sequence Milestones
Stakeholder / Agency
Associated
Recommended
Time Line for
Implementation
10d
Production of diesel from ERL
with sulfur content of 50 ppm or
less
ERL, BPC 2022
11 Import of diesel with 50 ppm or
less sulfur content
Ministry of Power,
Energy & Mineral
Resources, BPC,
Ministry of Finance
2023
12
Review of Road map for LSD
with less than 50 ppm sulfur
content
DoE, All Stakeholders 2025
** currently the sulfur content is planned to be reduced to 350 ppm, in case it is reduced to
50 ppm event 4 and 9 can be blended together.
*** Lead Organizations shown in Bold letters
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11. CONCLUSIONS
All the stakeholders generally agreed that it is necessary to reduce the sulfur
content of diesel fuel. The consultant team (BUET) is of the opinion that
proposing drastic reduction in the sulfur content in diesel from the existing
2500 ppm down to 50 ppm seems unrealistic given the socio-economic,
technological and political situations in Bangladesh. So it suggests a rather
pragmatic approach of going down the road in phases as it seems more
feasible for implementation.
Since more than 85% of HSD consumed in Bangladesh at present is imported
as the final product, BPC can start importing diesel with lower sulfur content.
However, 15% diesel comes as one of the products from processing crude oil
by ERL. Being a refinery established decades ago, ERL produces diesel with
higher sulfur content, but the associated products like HSFO, octane,
kerosene and petro-chemicals are essential fuels and raw materials for other
sectors. Currently, ERL diesel is being blended with imported one resulting in
a sulfur content of 2500 ppm which is the existing standard in Bangladesh.
Based on the socio-economic condition of Bangladesh as well as the global
and regional trends a roadmap for use of LSD in Bangladesh has been
proposed. Input and feedbacks from a wide range of stakeholders have been
sorted in a number of occasions, through seminars, focus group discussions,
field-visits and data collection.
The approach of gradual change from a HSD to LSD is considered to be more
pragmatic and realistically achievable in the socio-economic context of
Bangladesh. The road to use LSD is divided in three successive phases after
preliminary preparation work. This preparation phase in 2015 must include
activities involving - standardization of measurement procedure for sulfur
content in diesel fuel, up-gradation of emission control regulations for diesel
vehicles / engines, and introduction of prevention control measures against
fuel adulteration. Implementation of these three milestones is essential for
getting the real benefit of using LSD fuel for a better environment.
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Reduction of sulfur content to 500 ppm is proposed from 2016. After the
proposed renovation of ERL facilities this is suggested to be reduced to 350
ppm from 2020. From 2023, the whole system should be ready for using LSD
of 50 ppm. Important milestones with concerned timelines have been detailed
in the proposed roadmap. Intermediate review of the proposed roadmap is
essential which is proposed in 2019 and 2022. This would allow to
accommodate changes in national or global scenario along the timeline of the
roadmap.
The activities associated with the roadmap involve a wide range of
government and private bodies. A good co-ordination between associated
agencies will be essential. Keeping all such relevant stakeholders onboard is
essential for successful implementation of the proposed roadmap.
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12. FUTURE PLANS
The consultant team (BUET) proposes the roadmap up to the year 2025 including
recommendations for the revisions of the roadmap at a convenient time interval of
three/four years. However, in 2019 and then in 2022, the roadmap must be revised to
adapt to the then prevailing socio-economic, environmental, technological, political
and health situations of the country as well as the global trends.
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APPENDIX-A
(SUMMARY OF MEETINGS WITH FOCUS GROUPS AND STAKEHOLDERS)
Total six meetings were conducted from May 2013 to February 2014 at Dhaka and
Chittagong with all the stakeholders and some specific focus groups. The Focus Groups (FG)
consists of department of environment, vehicle business groups, government enforcement
authorities, Oil companies, Oil distributors and Oil refinery. In different meetings,
representatives from different organizations were present and the consultant representative
(BUET) initiated the discussion with a long time multimedia presentation. The participants
were given some specific questions relevant to their business / duties / research etc., the
discussions were most of the time continued on the basis of the questions and their
corresponding answers. In this appendix, the highlighted portion of the conducted meetings is
summarized.
The first meeting was held on May-28, 2013 at the Department of Environment (DoE),
Agargoan, Dhaka. The welcome speech mentioning the objectives of the meeting was
delivered by the Director (Planning), DoE, GOB. A presentation titled Fuel and Vehicle
Emission Standards: Trends in Asia, was delivered by a representative from Clean Air Asia
(CAA). She presented the current activities of CAA, goals for Asia up to 2016 regarding
Better Air Quality (BAQ). A technical consultant (from Dept. of Mechanical Engineering,
BUET) of this road map project, presented "Reducing Black Carbon from Heavy Diesel
Vehicles and Engines". He explained the emission formation mechanism from high sulfur
diesel engines and its remedy. He also asked for the co-operation from all the stake holders
for proposing a road map to get a diesel pollution free environment. Director General, DOE
and the Chair in his closing speech emphasized the need for clean air in Bangladesh. He said
that we need a simultaneous approach to improve fuel quality, control of vehicular emission
and introduce an efficient traffic management system.
The second meeting was held on July 29, 2013 at the Department of Environment (DOE),
Agargoan, Dhaka. The welcome speech mentioning the objectives of the meeting was
delivered by Director (Planning), DOE, GOB. He gave a brief account of DOEs involvement
on efforts taken towards lower emission and cleaner fuels. Participants and experts from
different relevant organizations (BRTA, DOE, representatives from Bus Owner Association,
representative from vehicle importers) were present on the occasion. Presentations were made
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by some of the experts, followed by comprehensive discussions and finally a number of
recommendations were put forward by all the participants.
The first presentation titled Reducing Black Carbon from Heavy Vehicles & Engines in
Bangladesh was delivered by Deputy Director (Engg.), Bangladesh Road Transport
Authority (BRTA), Dhaka. He started his presentation with a brief introduction of BRTA. He
presented the statistics of type-wise registration of vehicles up to 2009 and vehicles registered
in 2010, 2011 and 2012 in Bangladesh. According to the statistics of BRTA the total number
of registered vehicle in Bangladesh up to 2012 was 18,44,335. The number of registered
vehicle in Dhaka city up to 2012 was 7,25,597. He mentioned that vehicular emission is one
of major sources of air pollution in Bangladesh.
Technical consultant from the Department of Mechanical Engineering, Bangladesh
University of Engineering and Technology (BUET) presented Diesel Engine Emission
Technical Aspects. At first he presented the basic mechanism, characteristics and
applications of diesel engines. The combustion mechanism inside the engine cylinder and
pollution formation was explained in his presentation. He also presented the effect of
pollutants on health, environment and on engine itself. He presented and discussed the
existing technology for controlling the pollution from diesel engines. During his presentation
he emphasized on the quality of fuel for diesel engines and emissions from diesel engines. He
also discussed about the recent trends in diesel fuel in other countries. He focused on the
advantages and disadvantages of Low Sulfur Diesel (LSD) and Ultra-low Sulfur diesel
(ULSD). He informed the meeting that diesel containing high sulfur develops corrosion in the
cylinder, piston, piston rings and exhaust system. The emissions from diesel engines make
the emission control devices (like catalytic converter, DPF, etc) inactive when the engine
runs with high sulfur diesel. He also mentioned that low sulfur content in diesel reduces the
lubricity of diesel, which can be recovered by using some additive at some cost. His
conclusion was that the benefits of low sulfur fuels are much greater than the costs. Finally,
he suggested to take immediate action for the preparation of a road map and its
implementation for Low Sulfur Diesel (LSD) in Bangladesh.
A representative from vehicle importers informed that they import brand new diesel vehicles
which are designed for LSD and equipped with emission control devices (like catalytic
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converter, DPF, etc.) but due to unavailability of LSD they have to remove the emission
control devices from the vehicles.
Finally, the chairman summarized the presentations and emphasized for an emission free
Bangladesh. He focused on simultaneous approach among- fuel quality, vehicle emission,
traffic system and co-ordination between the relevant authorities. He thanked all the
participants and declared the meeting closed.
The first focus group meeting was held on August 04, 2013 in Chittagong with Bangladesh
Petroleum Corporation (BPC) and Eastern Refinery Limited (ERL) and all other oil
distribution companies of the Bangladesh. At the beginning Director (Planning), DoE, GOB
gave a brief description of the objectives of the project. Director (Marketing) of Bangladesh
Petroleum Corporation (BPC) presided over the meeting. There are about total thirty
participants from different disciplines of the above mentioned institution participated in the
group discussion. The technical consultants of the project from (BUET) informed the
participants about the advantages of using low sulfur diesel in engines and vehicles. The
consultation team also requested to BPC and ERL to provide some statistical data /
documents which will be helpful for preparing the road map of the present project. After a
two hours fruitful discussion, the chairman of the session assured the participants that BPC
will do its best to implement the project and to have a pollution free environment. He then
declared the closing of the discussion session.
After the focus group meeting, the consultation team members of BUET along with Director
(Planning), DOE, GOB participated in a field visit to ERL, Chittagong. DGM (planning and
shipping), ERL assisted the team to understand different process of ERL. The team also
visited the testing laboratory of ERL. The team members similarly requested to provide some
statistical data / documents of ERL for assisting the preparation of road map which is the key
objective of the project. Finally, BPC and ERL provided some useful data and the answers of
the questionnaires' which were distributed in the meeting.
The second focus group meeting was held on October 23, 2013 at Department of
Environment (DOE), Agargaon, Dhaka with presence of Diesel Vehicles Importers'
Association of Bangladesh and Bus-Truck Owners' Association of Bangladesh. The meeting
was usually began with a welcome speech delivered by Director (Planning), DOE, GOB
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mentioning the objectives of the meeting. Technical consultant from the Department of
Mechanical Engineering, Bangladesh University of Engineering and Technology (BUET)
provided a multimedia presentation. The consultant discussed very briefly the various
technical aspects of diesel engines and diesel vehicles with particular emphasis on diesel
emissions and their severe detrimental effects on environment and eventually to human
health. He also showed several emission control mechanism that can be employed in diesel
engines and diesel vehicles to reduce emissions. He put major emphasis on the quality control
of diesel fuel especially by reducing its sulfur content.
Representative from vehicle importers informed the meeting that Euro II/III vehicles cannot
be run without fuel correction. Also fuel statistics are required for newer vehicles import.
Another participant also informed that vehicles will not be available for running below Euro
IV standard after March, 2015. Regarding import from China, it was informed that Chinese
govt. is imposing severe restrictions on producing engines/batteries that cause environmental
pollution. So no conventional engines will be available after around March, 2015. Some
participants commented that the protection against the adulteration of lubricating oil and
diesel fuel is absolutely essential. Lub. oil adulteration is very dangerous for the lifespan of
the engines and/or vehicles. Finally, Director (Planning), DOE, again reiterated the need for
Clean air in Bangladesh by controlling the fuel quality with cooperation from all relevant
sectors. He thanked all the participants and closed the meeting.
The third Focus Group Consultation Meeting of Reducing Black Carbon from Heavy Duty
Diesel Vehicles and Engines was held on 15 January 2014 at the Department of
Environment, Agargaon, Dhaka. The particapants of the meeting were mainly from the
enforcement authorities of environment of Bangladesh, like BRTA, Traffic Police, DOE,
BSTI. The Director General, Department of Environment presided over the meeting. The
welcome speech was delivered by Director (Planning), DOE and PD, Reducing Black Carbon
from Heavy Duty Vehicles and Fuels. He mentioned that a limit of ppm of sulfur in diesel
fuel has already been emposed by the Government of Bangladesh before, the ongoing road
map project hope to propose a new diesel fuel standard to be implimented within certain
years.
The technical consultants of the project from BUET an outline of updating the roadmap for
clean fuels for vehicles and stricter emission standards for Heavy Diesel Vehicle (HDV) and
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Light Diesel Vehicle (LDV) in Bangladesh. He explained the advantages and disadvantages
of using high sulfur diesel (HSD) and low sulfur diesel (LSD). He highlighted his discussion
for the use of high sulfur content diesel, which is very much harmful for the environment.
The pollutants produced from the combustion of high sulfur content diesel is carsinogenic
that might cause cancer. This pollutents can also make the emission control devices of
engines invalid. He also mentioned the disadvantges of using low sulfur diesel like decrease
of the fuel lubricity, increase of the chance for the formation of organic compound in fuel.
The representatives from different enforcement authorities participated in a discussion
session. The representative from the traffic polic mentioned that though LSD is costly, it
should be used because life is more valuable than anything. The representative from BSTI
mentioned that they need to increase their capability to maintain / monitor the new standard
for diesel fuel which will be proposed in the coming road map. The DOEs representative
highlighted that the sulfur ppm in diesel vary from the supply source (Eastern Refinery
Limited) to petrol pump i.e. there can be a survey if there is any adulteration during
transportation / distribution of fuel.
Finally, Chairman of this discussion meeting, delivered his concluding remarks and declared
the meeting close. He promised to do everything for a pollution free environment.
The fourth Focus Group Consultation Meeting of Reducing Black Carbon from Heavy Duty
Diesel Vehicles and Engines was held on 25 February 2014 at the Department of
Environment, Agargaon, Dhaka. The participants of the meeting were mainly from the
Diesel-Petrol Pump Owners Association, Generator Importers and Private Sector Power Plant
Companies. The Director General, Department of Environment presided over the meeting.
The welcome speech was delivered by the Director (Planning), DOE and PD of Reducing
Black Carbon from Heavy Duty Vehicles and Fuels. He mentioned that DoE has invited all
major stakeholders of this environmental issue in a series of Focus Group Discussion
(FGD) meetings to get their respective views. Only with involvement and coordination
among the stakeholders an effective roadmap can be proposed.
The representative from BUET, as a technical consultant of this road map project, presented
an outline for Reducing Black Carbon from Heavy Duty Vehicles and Fuels. He explained
health effect of diesel pollution and the objectives of using low sulfur content diesel.
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Different ways of reducing air pollution due to combustion of diesel and effect of sulfur
content of fuel on them was highlighted. He also mentioned the advantages and
disadvantages of using low sulfur diesel (LSD). Finally, he concluded that we should go for
LSD to cope with the rest of the world
The representative from petrol pump owners association boldly delivered his long practical
experience in the meeting. He mainly talked about the adulteration of fuel (including diesel)
in different stages of handling from port up to the end user (i.e. the vehicle users). He believe
that there is wide spread adulteration of fuels and finally, he recommended that all the
concern authorities should be under accountability. He emphasized that without proper
control of adulteration at field level all the efforts for reducing pollution by improvement of
fuel quality may prove to be fruitless.
The representative from diesel generator power plants informed the meeting that the
generating capacity of liquid-fuel run power plant in and around Dhaka city is about 300 MW
and near future it may meet 1000 MW. They are using heavy fuel oil (HFO) of certain type
that meet the specified requirement of fuel set by the engines' manufacturers. Generally the
sulfur content of HFO is pretty high, but there was no reliable measurement record so far. In
some cases the foreign donors ask for emission requirement but de-sulfurizing units are still
very uncommon. The representative from generator importer association informed the
meeting that still they have no restriction of sulfur content in fuel for running their engines
used to run the generator for producing electricity. He also informed that in future they might
undergo the sulfur content restriction for their usable fuels.
One representative from vehicle importer association was present in the meeting. He briefed
that for recent models of vehicles, their fuel quality requirement could not be met by the
available fuel in the market in Bangladesh. Some important parts like fuel pumps, injectors
and emission control devices become out of order due to low quality fuels. He also informed
that the latest and high efficient vehicles have high demand but the available fuels in
Bangladesh do not permit to import those vehicles. Modern diesel emission control devices
like DPF, DOC or SCR are rarely used in vehicles imported in Bangladesh, although there
are vehicular emission rules implemented from 2006.
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At the end of the discussion, Chairman of the meeting, delivered his concluding remarks and
declared the meeting close. He requested everybody to work together in a coordinated way
for a pollution free environment.
The discussion Meeting of Reducing Black Carbon from Heavy Duty Diesel Vehicles and
Engines at its mid-term stage was held on 09 April 2014 at the Department of Environment,
Agargaon, Dhaka. The participants of the meeting were mainly from the representative from
DoE, Clean Air Asia (CAA), Vehicle Importer Association, Communication Ministry, BSTI,
Ministry of Energy and Mineral Resouces, Science Laboratory and Bus-Truck Owner
Association. Mr. Md. Raisul Alam Mondal, Director General, Department of Environment
presided over the meeting. The welcome speech was delivered by Mr. Quazi Sarwar Imtiaz
Hashmi, Director (Planning), DOE and PD of Reducing Black Carbon from Heavy Duty
Vehicles and Fuels. He mentioned about the objectives of the present meeting. The time line
roadmap for sulfur (ppm) reduction in diesel and the recommendation regarding
improvement of Eastern Refinery Limited (ERL) were the main discussion topic.
Dr. Nurul Quadir, Joint Secretary (Environment) and Focal Point, Reducing Black Carbon
from Heavy Vehicles and Fuels discussed about the participation of Bangladesh for reducing
world environmental pollution. Mr. Md. Yunus Ali, Chief Conservator of Forests,
Bangladesh Forest Department delivered his speech highlighting that a combined initiative by
different authorities like BRTA, ERL, Commerce Ministry, Vehicle Importers, Fuel
Distributors can create a pollution-free Bangladesh. Mr. Rafiqul Islam, Chief Guest and
Additional Secretary (Environment), Ministry of Environment and Forests delivered his
speech mentioning that with the cooperation from all, the present initiative can certainly
produce a fruitful roadmap for reducing the black carbon. He mentioned is our constitutional
duty to create a pollution free environment.
Prof. Dr. Maglub Al Nur, Department of Mechnaical Engineering, BUET, technical
consultant of this road map project, presented the draft roadmap to the forum for discussions
and recommendations. He highlighted the disadvantages of using high sulfur content diesel.
He mentioned that in two ways pollution can be controlled; one is by using post ignition
devices (like catalytic converter, DPM etc.) and the other is by using good quality fuels. He
presented sulfur level in diesel in different countries. He also informed the production,
import, consumption and sales data of HSD and HFO by ERL and BPC. He mentioned the
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blending statistics of ERL and their new proposal for plant development. He presented some
observations and findings related to HSD and its production, emission and adulteration.
Finally, he presented the draft proposal for the roadmap for Reducing Black Carbon from
Heavy Duty Diesel Vehicles and Engines in Bangladesh. He presented two options for the
sulfur content (ppm) reduction and timeline for the roadmap in the proposed draft and invite
the participants for the open discussion. Representative from Vehicle Importers informed the
participants that at the moment the major vehicle manufacturers are producing vehicles
compatible for only high quality (low sulfur) fuel and due to low quality fuel in Bangladesh
their sales volume is decreasing. He shared his experience of testing fuel samples at foreign
laboratories collected from Dhaka showing high level of sulfur.
A representative from communication ministry informed that due to use of Low Sulfur Diesel
(LSD), the cost for transportation will be increased and therefore all the relevant departments
of communication ministry should invite in future meeting. The increase of price should also
ensure the low sulfur content of the fuel. Representative from BSTI informed the forum that
ERL needs desulfurization plant for producing LSD. Representative from Energy Ministry
informed that the cost of diesel per liter will increase if LSD is imported. To do so,
government needs more subsidy or have to solve the problem for increasing transportation
cost. Therefore, a rigorous economic analysis has to be performed to propose the roadmap.
One representative from Science Laboratory mentioned that BSTI should be more active to
get a standard that is necessary for pollution free environment.
Two representatives from Clean Air Asia (CAA) were present in the meeting. They were
informed about the proposed road map and contents of discussion. Mr. Md. Raisul Alam
Mondal, Chairman of this discussion meeting, delivered his concluding remarks and declared
the meeting close. He expressed his opinion that to get a healthy environment, we have to
maintain standard of fuel quality up to the end users.
The Fifth Focus Group discussion Meeting of Reducing Black Carbon from Heavy Duty
Diesel Vehicles and Engines was held on 25 June 2014 at the Department of Environment,
Agargaon, Dhaka. The participants of the meeting were mainly from the representatives of
DoE, BADC, BSTI, BRTC, ERL, Communication Ministry, Ministry of Energy and Mineral
Resouces.
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Mr. Md. Shahjahan, Additional Director General, Department of Environment presided over
the meeting. The welcome speech was delivered by Mr. Quazi Sarwar Imtiaz Hashmi,
Director (Planning), DOE and PD of Reducing Black Carbon from Heavy Duty Vehicles
and Fuels. He mentioned that among the most polluted cities in the world, Bangladesh
belongs to top few of them. He requested all the participants to finalize the road map for
making a pollution free Bangladesh.
Prof. Dr. Md. Mamun, Department of Mechnaical Engineering, BUET and technical
consultant of this road map project, presented the roadmap (draft) to the forum for
discussions, recommendations and suggestions for getting it implemented. He discussed the
disadvantages of using high sulfur content diesel. He presented sulfur level in diesel in
different countries. He mentioned the blending statistics of ERL and their new proposal for
plant development. Finally, he presented the draft proposal for the roadmap for Reducing
Black Carbon from Heavy Duty Diesel Vehicles and Engines in Bangladesh. He described
two options for the timeline of the roadmap in the proposed draft and invited the participants
for the open discussion.
Representative from Department of Electricity proposed that the blending by ERL for diesel
should be stopped soon; Prof. Ehsan explained that ERL processes crude oil not only for
producing diesel, a number of other fuels like Petrol/Octane, Kerosene, Jet fuels as well as
raw materials for a number of petro-chemical industries are also produced in this process.
Hence it is not practical to stop blending unless a separate market for the diesel produced by
ERL is found and this process may need some time. It was stated that there may be possibility
of using ERL diesel in a section of the power generation facilities, but the feasibility needs to
be explored.
Representative from BSTI mentioned that they have some meetings for making a standard of
