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The Texas Low Emission Diesel (TxLED) Program requires that TxLED-compliant fuel be sold or supplied year-round for use in all diesel engines for both on-road vehicles and off-road equipment operating within 110 central and eastern Texas counties. At this time, the TxLED program has not been fully implemented. Currently, a rulemaking project is underway to reevaluate the EPA and TCEQ approval processes for alternative fuel formulations and alternative emissions reductions plans. This article explains the purpose and origin for the TxLED program; the types of TxLED-compliant fuel; and the basis for concerns about price, supply, and quality of TxLED-compliant fuel.
The TxLED program is attempting to reduce NOx emissions from on-road and off-road diesel engines and therefore is part of TCEQ's plan to demonstrate "ozone attainment" for the ozone nonattainment areas in central and eastern Texas. |
The origin of the program dates back to 2000 when the North Texas Clean Air Steering Committee representing the Dallas/Fort Worth (DFW) area nonattainment counties asked the TCEQ to use a "fuel-based strategy" for reducing NOx emissions. At this time, the rule was only applicable to a 9-county area around DFW; however, during a subsequent rulemaking session in 2000, TCEQ expanded the TxLED program to include all counties in Texas. In 2001, the 77th Legislature statutorily prevented TCEQ from implementing the TxLED program prior to January 1, 2005. During the Fall of 2001, TCEQ revised the program to require TxLED in only the central and eastern portions of the state (i.e. counties that include and that are east of I-35 and I-37). On March 9, 2005, TCEQ extended the compliance date for the Texas low emission diesel fuel standards by six months.
According to TCEQ, there will be an adequate supply of TxLED-compliant fuel to satisfy demand; however, little data has been requested or reviewed regarding the effect of TX LED-compliant fuel, including additives, on the performance and reliability of heavy duty engines. Therefore, the reliability issue of TX LED-compliant fuel remains unresolved.
What is TxLED-compliant fuel?
TxLED-compliant fuel consists of fuels that were approved as low emission fuels by the California Air Resources Board, as well as fuels that were developed under an alternative fuel formulation or alternative emission reduction plan. TxLED-compliant fuel can also be "true TxLED," which is fuel that is produced to meet the TxLED fuel specification that requires a minimum cetane of 48 and maximum aromatic content of 10%. As noted, the TxLED program originally required producers and importers of diesel fuel to produce a new or specialized diesel fuel formula for use in the nonattainament counties near the DFW area. As the program developed, it became clear that some fuel producers would not produce TxLED fuel, so additional strategies that included the use of additives and alternative emission reduction plans were implemented to ensure an adequate supply of TxLED fuel would be available. To date, the five different types of TxLED-compliant fuel include:
- Diesel fuel that has a maximum aromatic hydrocarbon content of 10 percent by volume and has a minimum cetane number of 48 (i.e. True TxLED).
- Diesel fuel that complies with the specifications of a California Air Resources Board (CARB) certified alternative diesel formulation that was approved by CARB before January 18, 2005, to meet California diesel regulations in effect as of October 1, 2003. CARB certified alternative diesel formulations that were approved for compliance with California's small refinery specifications for diesel fuel are not acceptable (i.e. CARB-approved).
- Diesel fuel that complies with California diesel fuel regulations in effect as of January 18, 2005, except for those regulations established for small refineries. Diesel fuel produced to comply with the "designated equivalent limits" specified in the California diesel regulations would also be considered compliant with the TxLED fuel standards (i.e. CARB-approved alternative).
- Diesel fuel that complies with an alternative diesel fuel formulation that has been approved by TCEQ as achieving comparable or better emission reductions (i.e. Alternative Formulation Fuel).
- Diesel fuel under an alternative emission reduction plan that has been approved by TCEQ and the U.S. Environmental Protection Agency (EPA) which contains a substitute fuel strategy that will achieve equivalent emission reductions (i.e. Alternative Emission Reduction Plan Fuel).
Why is there a concern regarding price, supply, and quality?
Since 2000, TCEQ has stated that it will cost an additional $0.04-0.08 per gallon to produce TxLED compliant fuel; however, the actual market price that end-users will pay for TxLED-compliant fuel is uncertain. For example, some fuel additive vendors conservatively estimate that it may cost end-users as much as an additional $0.10 per gallon to purchase TxLED-compliant fuel, and considering that some municipalities and private companies use large quantities of diesel fuel (e.g. in excess of 500,000 gallons per year), this cost increase will be significant. Given that Texas is relying on an "additive-based" fuel strategy to implement the TxLED program, additional modifications to the refueling infrastructure (e.g. new tanks; larger pumps; and environmental permits) will be necessary to adequately distribute TxLED-compliant fuel to urban and rural areas affected by the TxLED program.
In addition to concerns related to price and distribution, end-users would be wise to plan for additional maintenance checks on fleet vehicles and heavy duty equipment. Why? The simple answer is that the TxLED program does not have a "quality-based" testing or approval component for additized fuels. According to TCEQ, all TxLED-compliant fuels must meet a basic fuel specification (i.e. ASTM-D975); and therefore, quality is ensured. As another quality-check, TCEQ notes that all fuels and additives must be "registered" with the EPA. Unfortunately, the EPA registration process, which concerns emissions and health-effects testing, does not take into account the effect of the fuel or additive on engine wear parts or performance. In fact, little or no information is readily available regarding the effects of new additives on stationary, heavy duty diesel engines or on fuel performance.
Path Forward/Conclusion:
While the TxLED Program continues to evolve, the recent hurricanes that struck the Louisiana and Texas Gulf Coast caused the Governor's Office and TCEQ to delay the implementation of the TxLED compliance dates by 30 days. The TCEQ is hosting its first TxLED Stakeholders' meeting on Friday, October 14th to discuss additional revisions and implementation measures for the rule. TxSWANA will be represented at this meeting and specific questions regarding price, supply, and quality will be raised to fuel producers and TCEQ Staff. Regardless of perspective, the TxLED program will significantly affect producers and users of diesel fuel, and representatives of these groups should work together to effectively implement this rule.
TxLED-compliant fuel consists of fuels that were approved as low emission fuels by the California Air Resources Board, as well as fuels that were developed under an alternative fuel formulation or alternative emission reduction plan. TxLED-compliant fuel can also be "true TxLED," which is fuel that is produced to meet the TxLED fuel specification that requires a minimum cetane of 48 and maximum aromatic content of 10%. As noted, the TxLED program originally required producers and importers of diesel fuel to produce a new or specialized diesel fuel formula for use in the nonattainament counties near the DFW area. As the program developed, it became clear that some fuel producers would not produce TxLED fuel, so additional strategies that included the use of additives and alternative emission reduction plans were implemented to ensure an adequate supply of TxLED fuel would be available. To date, the five different types of TxLED-compliant fuel include:
- Diesel fuel that has a maximum aromatic hydrocarbon content of 10 percent by volume and has a minimum cetane number of 48 (i.e. True TxLED).
- Diesel fuel that complies with the specifications of a California Air Resources Board (CARB) certified alternative diesel formulation that was approved by CARB before January 18, 2005, to meet California diesel regulations in effect as of October 1, 2003. CARB certified alternative diesel formulations that were approved for compliance with California's small refinery specifications for diesel fuel are not acceptable (i.e. CARB-approved).
- Diesel fuel that complies with California diesel fuel regulations in effect as of January 18, 2005, except for those regulations established for small refineries. Diesel fuel produced to comply with the "designated equivalent limits" specified in the California diesel regulations would also be considered compliant with the TxLED fuel standards (i.e. CARB-approved alternative).
- Diesel fuel that complies with an alternative diesel fuel formulation that has been approved by TCEQ as achieving comparable or better emission reductions (i.e. Alternative Formulation Fuel).
- Diesel fuel under an alternative emission reduction plan that has been approved by TCEQ and the U.S. Environmental Protection Agency (EPA) which contains a substitute fuel strategy that will achieve equivalent emission reductions (i.e. Alternative Emission Reduction Plan Fuel).
Why is there a concern regarding price, supply, and quality?
Since 2000, TCEQ has stated that it will cost an additional $0.04-0.08 per gallon to produce TxLED compliant fuel; however, the actual market price that end-users will pay for TxLED-compliant fuel is uncertain. For example, some fuel additive vendors conservatively estimate that it may cost end-users as much as an additional $0.10 per gallon to purchase TxLED-compliant fuel, and considering that some municipalities and private companies use large quantities of diesel fuel (e.g. in excess of 500,000 gallons per year), this cost increase will be significant. Given that Texas is relying on an "additive-based" fuel strategy to implement the TxLED program, additional modifications to the refueling infrastructure (e.g. new tanks; larger pumps; and environmental permits) will be necessary to adequately distribute TxLED-compliant fuel to urban and rural areas affected by the TxLED program.
In addition to concerns related to price and distribution, end-users would be wise to plan for additional maintenance checks on fleet vehicles and heavy duty equipment. Why? The simple answer is that the TxLED program does not have a "quality-based" testing or approval component for additized fuels. According to TCEQ, all TxLED-compliant fuels must meet a basic fuel specification (i.e. ASTM-D975); and therefore, quality is ensured. As another quality-check, TCEQ notes that all fuels and additives must be "registered" with the EPA. Unfortunately, the EPA registration process, which concerns emissions and health-effects testing, does not take into account the effect of the fuel or additive on engine wear parts or performance. In fact, little or no information is readily available regarding the effects of new additives on stationary, heavy duty diesel engines or on fuel performance.
Path Forward/Conclusion:
While the TxLED Program continues to evolve, the recent hurricanes that struck the Louisiana and Texas Gulf Coast caused the Governor's Office and TCEQ to delay the implementation of the TxLED compliance dates by 30 days. The TCEQ is hosting its first TxLED Stakeholders' meeting on Friday, October 14th to discuss additional revisions and implementation measures for the rule. TxSWANA will be represented at this meeting and specific questions regarding price, supply, and quality will be raised to fuel producers and TCEQ Staff. Regardless of perspective, the TxLED program will significantly affect producers and users of diesel fuel, and representatives of these groups should work together to effectively implement this rule.
Since 2000, TCEQ has stated that it will cost an additional $0.04-0.08 per gallon to produce TxLED compliant fuel; however, the actual market price that end-users will pay for TxLED-compliant fuel is uncertain. For example, some fuel additive vendors conservatively estimate that it may cost end-users as much as an additional $0.10 per gallon to purchase TxLED-compliant fuel, and considering that some municipalities and private companies use large quantities of diesel fuel (e.g. in excess of 500,000 gallons per year), this cost increase will be significant. Given that Texas is relying on an "additive-based" fuel strategy to implement the TxLED program, additional modifications to the refueling infrastructure (e.g. new tanks; larger pumps; and environmental permits) will be necessary to adequately distribute TxLED-compliant fuel to urban and rural areas affected by the TxLED program.
In addition to concerns related to price and distribution, end-users would be wise to plan for additional maintenance checks on fleet vehicles and heavy duty equipment. Why? The simple answer is that the TxLED program does not have a "quality-based" testing or approval component for additized fuels. According to TCEQ, all TxLED-compliant fuels must meet a basic fuel specification (i.e. ASTM-D975); and therefore, quality is ensured. As another quality-check, TCEQ notes that all fuels and additives must be "registered" with the EPA. Unfortunately, the EPA registration process, which concerns emissions and health-effects testing, does not take into account the effect of the fuel or additive on engine wear parts or performance. In fact, little or no information is readily available regarding the effects of new additives on stationary, heavy duty diesel engines or on fuel performance.
Path Forward/Conclusion:
While the TxLED Program continues to evolve, the recent hurricanes that struck the Louisiana and Texas Gulf Coast caused the Governor's Office and TCEQ to delay the implementation of the TxLED compliance dates by 30 days. The TCEQ is hosting its first TxLED Stakeholders' meeting on Friday, October 14th to discuss additional revisions and implementation measures for the rule. TxSWANA will be represented at this meeting and specific questions regarding price, supply, and quality will be raised to fuel producers and TCEQ Staff. Regardless of perspective, the TxLED program will significantly affect producers and users of diesel fuel, and representatives of these groups should work together to effectively implement this rule.
While the TxLED Program continues to evolve, the recent hurricanes that struck the Louisiana and Texas Gulf Coast caused the Governor's Office and TCEQ to delay the implementation of the TxLED compliance dates by 30 days. The TCEQ is hosting its first TxLED Stakeholders' meeting on Friday, October 14th to discuss additional revisions and implementation measures for the rule. TxSWANA will be represented at this meeting and specific questions regarding price, supply, and quality will be raised to fuel producers and TCEQ Staff. Regardless of perspective, the TxLED program will significantly affect producers and users of diesel fuel, and representatives of these groups should work together to effectively implement this rule.
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