SUMMARY OF COMMENTS,

SUMMARY OF COMMENTS, RESPONSES AND MODIFICATIONSA Road Map for Cleaner Fuels and Vehicles in AsiaSecond Consultation Draft 19 December 2007
Introduction.The second consultation draft of the Road Map for Cleaner Fuels and Vehicles for Asia was posted on the CAI-Asia website on 19 December, 2007. This summary comments matrix contains an overview of the main comments received, the responses of the authors and the modifications that are proposed to the report based on the comments received and responses outlined. The full comments received can be viewed (atComments will be posted after this summary of comments is distributed) This summary does not contain the editorial and factual corrections proposed in the comments.Department of Energy, Philippines. A. CommentsWe have to also consider fuel sources, both local and international. At the moment, for the Euro 2 fuels, we still directly import 40% of our present requirement as finished products because our local refineries cannot even meet all of their respective demands. So the question is, can there be sufficient source for the Euro 4 fuels which we may have to import completely? With the high and increasing fuel prices, can our people (in general) afford?B. Responses:We are aware that changes would be required in the refinery infrastructure both in the Philippines and elsewhere. That is also why the Road Map recommends a lead time of several years. With respect to cost, the argument made in the Road Map is that the cost per liter of Euro 4 fuel is not that much higher; 0.18 to 0.8 US cents per liter for gasoline, and 0.53 to 0.8 US cents for diesel. Asian economies, including the Philippines, have demonstrated that higher fuel prices can still go together with high(er) economic growth.
C. Modifications to the Road Map:No need for changes.sian Clean Fuels Association A. Comments:In general, we find that the facts on ethers such as MTBE and ETBE contained in the document are rather US-centric and do not adequately present the viewpoints of other regions, in particular the EU.
In Finland, the widespread use of oxygenated fuel containing 9-13% MTBE has reduced CO emissions by 10-20% and hydrocarbons by 5-10%.The preponderance of evidence shows that, the enormous air quality benefits of fuel oxygenates—reductions in carbon monoxide, particulate matter, air toxics, off-road emissions and stationary source emissions—will be effective and useful in automobile engines for years to come..Based on their own experience and experiments with fuels quality, the world automakers also prefer MTBE. In the Worldwide Fuel Charter (WWFC) published by the automakers from USA, Europe and Japan, they have collectively recommended that “when oxygenates are used, ethers are preferred”. This recommendation is based on their past experience with impurities in ethanol that have lead to degradation of fuel systems. Also the automakers are aware that the usage of ethanol blended gasoline may require other fuel changes to mitigate evaporative and exhaust emission impacts. Hence their preference over ethers such as MTBE and ETBE over alcohols.In 1997, MTBE was selected for risk assessment under the European Union (EU) Existing Substances Regulation. The EU risk assessment, conducted according to the regulatory framework established by the EU’s technical agencies, evaluated health and environmental data, together with the potential for human exposure and occurrence, to assess the over-all risk potential posed by MTBE. The EU risk assessment for MTBE was published December 2001 in the Official Journal of the European Communities. The European Union found that in “view of the lacking of limited relevance of the (animal cancer research) findings for man, and the low potency demonstrated in animal studies, human cancer risk is presumed to be low.” The assessment went on to conclude that consumers are NOT expected to be at risk from exposures to MTBE, and that protective measures already being applied are considered sufficient.With the abundance of scientific evidence supporting the continuing usage of MTBE, it is now viewed as an important tool to cost effectively meet improved gasoline standards in reducing emissions in a cost-effective and efficient manner. Response:The Road Map reflects the opinions expressed in the ACFA comments that the health risks of the use of oxygenates especially MTBE and ETBE as a fuel additive are not significant (para. 272- 276, 277, Road Map). The banning of the use of MTBE in California and Australia and the phase out in the USA is on the basis of its spoiling impact on groundwater in the case of leakage. In Europe and other countries where MTBE is allowed the risk of groundwater contamination is addressed by mandating specific types of underground storage tanks. The impacts of oxygenates (MTBE) on vehicle emissions are already well covered in the different sections of the Road Map
Modifications to the Road Map:
There is no mention of the importance of phosphorus (P) as a catalyst poison. P can be introduced in additives such as detergents. The effect is well known and as a result the addition of P-containing compounds to gasoline is prohibited in European standard EN228 and similar standards (e.g. Kenya KS275:2005) and there are limits in the US (0.0013g/l P), Australia and other countries. On the topic of impacts of MMT on emission control devices: AECC believes it would be more appropriate to refer to published material regarding the formation of deposits of oxidized manganese. Suggested references are: o Version 4 of World Wide Fuel Charter Volkswagen AG, Impact of MMT on vehicle emission performance,Asian Vehicle Emission Control Conference 2004 (AVECC 2004) - Beijing, China 27-29 April 2004, Presentation by M. J. Hawkins on behalf of ACEA, IPIECA meeting on lead phase out -o Shannon, Ireland, 10-11 September 2001o U. Panzer & H. Künne, Volkswagen Experience concerning MMT as a Gasoline Additive;Hart´s World Fuels Conference on Refinery Planning & Strategy for Europe - Madrid, 15 November 2001o Failure investigation report on Plugged catalyst and related documents, provided DeltaMotor Corporation (South Africa) to participants of the IPIECA meeting on lead phase out, Shannon, Ireland, 10-11 September 2001o Jack D. Benson - AFE Consulting Services, Inc. & Gregory J. Dana - Alliance of Automobile Manufacturers AAM; The Impact of MMT Gasoline Additive on Exhaust Emissions and Fuel Economy of Low Emission Vehicles (Lev), Response:
The Road Map mentions the impact of high sulfur concentrations in fuel on the performance of catalysts. Reference will be included to the role of P as an additive. The World Wide Fuel Charter is already referenced in the Road Map. The comments from AECC related to the impact of MMT on vehicle emissions do not question the conclusions reached it is suggested to add more references..
Modifications to Road Map:
Reference was included on the role of P as an additive in terms of spoiling the catalyst (para.98, Road Map). Those references that are in the public domain: “Schindler” and “Benson” were added as references (footnote 67, Road Map).
IV. Afton Chemical
A. Selective reference to papers:
1. Comments: the Road Map selectively references and interprets technical papers, and omits new and significant published scientific studies on the automotive environmental and health impacts of MMT® use. Afton’s comments include information that was previously presented by Afton in prior comments to CAI, provides additional new information and references, and responds to inaccurate statements.Responses:
Concerning the coverage of references in the Road Map: There are hundreds of studies in the scientific literature on the topic of health effects of manganese and MMT (from which Afton has selected a relative few) and a full and fair review of every possible study would require a panel of scientists and at least 18 months. That is why the Road Map relies on the reviews that have already been conducted by international health agencies (who have reviewed all of the Afton studies and hundreds more).The Road Map references several of these studies; there is specific reference to a number of these studies in paragraph 289 on EPA testing, including the website where the comprehensive reports of those studies, and not just the peer reviewed articles, can be found. (Federal Docket Management System (FDMS) at identified by docket number One additional reference explicitly related to the Afton-funded Toronto exposure study will be added as well as the risk assessment by the National Industrial Chemicals Notification and Assessment Scheme (NICNAS), which is the most recent government risk assessment Some of the studies quoted, especially on the impact of MMT on engine technology refer to technologies in use in the 1980’s and early 1990’s and their relevance to new, current, engine technology and emission control devices is questionable. (See section D2 below). The Road Map provides recommendations on the use of specific types of additives. Prudence has been given to integrating information from parties that manufacture and distribute specific types of additives. . Modifications to Road Map:
As explained above several of the individual health related reports listed by Afton have been included in the risk assessments by Health Canada, NICNAS and US-EPA. An additional reference explicitly related to the Afton-funded Toronto exposure study (footnote 48, Road Map) were added as well as the risk assessment by the Australian National Industrial Chemicals Notification Section (NICNAS) (footnote 43, Road Map).
B. Health Impacts of MMT
1. Comments:
After 30 plus years of use and countless studies MMT ® has never been shown to be unsafeThe scientific record for MMT® and its potential impact on public health is voluminous. For this reason, reasonable scientific judgments about the safety of MMT® can readily be made, especially in comparison to other additives and components of gasoline such as benzene, 1,3-butadiene, MTBE, and ethanol. For example, when assessing MMT® in December of 2001, Health Canada concluded that it “has no objection to the use of MMT.” Health Canada explained that, “based on its assessment of the scientific evidence . . . the amount of scientific information on the neurotoxicity of and exposure to manganese is substantial compared to the equivalent information on the toxicity and potential exposures associated with some of the alternatives.”Status of the ICOH Scientific Committees on Neuro-toxicology and Psychophysiology and Toxicology of Metals conclusion on the use of organic manganese compounds to gasoline was a consensus from a meeting rather than formal Committee position
Responses:
The argument made in the Road Map Document is that it has not been proven that the use of MMT is safe. This is important from a viewpoint of environmental regulation. As explained in the section below on the application of the precautionary principle, the lack of full scientific evidence combined with the threat of serious or irreversible damage can be considered as reasons for applying the precautionary principle. .
It is correct that both Health Canada in 2001 and the Australian National Industrial Chemicals Notification Section (NICNAS) in 2003 reviewed the literature relating to MMT. Although they concluded that the use of MMT did not appear to pose undue risks in their countries, it is important to place those recommendations in the context in which they were made – that is in countries with highly developed environmental regulatory systems and fuel quality enforcement mechanisms that can assure that any additive is used only in the low levels allowed. For example, in the NICNAS report, they note that, among other things, “MMT is highly toxic to aquatic organisms,” “MMT is highly toxic in animals and humans,” and “accidental ingestion, especially from aftermarket additives, of MMT “represent(s) a significant acute health risk to children.” Based however, on the extensive environmental protection and fuel quality controls that Australia has in place, they conclude that exposure is likely to be low, and that the “overall public health risk from MMT…is low.”
No Asian developing country has in place today, nor is likely to have in place in the near future, systems for controlling fuel quality comparable to Australia, so there is very limited ability in Asia to assure that these low levels of exposures will be obtained and that overall public health risk in Asia will in fact be this low. Thus care needs to be exercised in applying the same safety conclusions for developing Asian countries.
The existence of uncertainty on the health impacts of MMT is evidenced by the fact mentioned in the Road Map that USEPA is requiring Afton to conduct a multi-year testing program on the health impacts of MMT use. This multi-year testing, which is still ongoing, was not stopped because of the information from the above mentioned studies. Also, in 2007, as indicated in the Road Map, the European Union in new draft legislation is proposing a ban on the use of MMT and international groups such as International Commission on Occupational Health (ICOH), in 2006, have called for a stop on the use of MMT. The on-going health studies in combination with other information on the harmful impact of metallic additives, as well as the recent 2007 proposed legislation in the EU, which calls for a ban on the use of MMT in gasoline from 1 January 2010 onwards (see for current status of legislation), justify a cautious approach on the side of regulators in Asia, and the application of the precautionary principle. Such widespread concerns do not exist with respect to other fuel additives, especially oxygenates, which have generally not been seen to equal (potential) negative impacts.
The scientific record on the health effects of manganese and MMT is voluminous, and neither the Afton comments (which selectively quote the literature) nor the Road Map (which identified a subset of key studies to cite that appeared to be most relevant to the questions at hand) could possibly cite all of them. They include studies of exposure to and health effects of manganese, manganese in different forms, and MMT. It is correct that only a full-fledged review by public health agencies can fully account for this which is why the Road Map called for Asian countries to pay special attention the new health review that Health Canada is doing and the ongoing testing requirements of MMT from the USEPA.
It is technically correct that the Brescia Declaration is the conclusions of a workshop convened by the Scientific Committees on Neurotoxicology and Psychophysiology of Metals of ICOH rather than a conclusion of the two committees. However, the conclusions have subsequently been published in both the Newsletter of the ICOH (Volume 4, No. 3, December 2006), and in the American Journal of Industrial Medicine 2007 (Volume 50 No. 10, Pages 709-711, 2006) Available: so they are validly included as scientific conclusions regarding metals in general and manganese in particular.
The removal of lead has been a prolonged effort that has resulted in a high cost in terms of mortality and morbidity (especially on the cognitive development of children) in Asia. It is for this reason that many of the same health experts who studied the health effects of lead are very concerned about replacing lead with another metallic additive - the effects of which could be serious neurotoxic (and other)concerns, especially in the long term. With lead it took a considerable amount of time before the chronic effects of lead were fully acknowledged and reflected in policy making and this time was even longer in Asia. There are similarities between the use of lead and MMT and their regulation. Awareness on the harmful impact and subsequent regulation started in Europe and California before it was taken over by other part of the world. Concerns on the use of MMT have resulted in an almost complete removal of the additive from use in Europe and the USA while it is until now only selectively used in Asia.
Modifications to the Road Map
The Road Map takes into account the NICNAS study and included main findings on the toxicity of MMT, the risks posed by the use of MMT as a fuel additive and place these into the prevailing regulatory capacity and its enforcement in developing countries in Asia. The Road Map clarifies the status of the Brescia Statement as the outcome of a workshop, which was subsequently published in the Newsletter of ICOH and the American Journal of Industrial Medicine .