The University of Sydney

Department of Infectious Diseases and Immunology NSW 2006 Australia

INQUIRY INTO MANDATORY ETHANOL AND BIOFUELS TARGETS IN VICTORIA

by

Assoc. Professor Ray Kearney OAM

c/-

24 Alder Avenue

Lane Cove West

NSW , 2006

Email: <rkearney@med.usyd.edu.au>

1st August, 2007

Declaration This Response, in the time provided, has been undertaken with the best of my ability and knowledge, based on materials, documents available and current information, as well as over 15 years involvement with air-quality issues. This includes campaigning for filtration to remove Sydney’s tunnel-stack pollution, specifically from the M5 East, Cross City and Lane Cove Tunnels. Its presentation is true and does not, by its presentation of information or omission of information, materially mislead or intend to materially mislead.

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TERMS OF REFERENCE

PARLIAMENTARY COMMITTEES ACT 2003

INQUIRY INTO MANDATORY ETHANOL AND BIOFUELS TARGETS IN VICTORIA

That the Economic Development and Infrastructure Committee to inquire into, consider and report to Parliament on mandatory ethanol and biofuels targets in Victoria – and, in particular, the Committee is required to :

a) report on the merits or otherwise of a mandated target for alternative fuels including biofuels and ethanol;

b) report on whether a mandatory target should be 5% by 2010, 10% by 2015 or otherwise;

c) report on the measures required by Government to facilitate an alternative fuels industry in Victoria for transport and non-transport applications; and

d) report on how to maximise the regional economic development benefits of a mandatory biofuels target including jobs growth and investment potential.

The Committee is required to report to Parliament by 31 March 2008.

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Recommendations • The author advocates the expansion of the market for domestically produced renewable

biofuels to reduce Australia’s dependence on imported petroleum, spur rural economic development creating new jobs and tax revenue, and improve environmental quality by reducing emissions of harmful pollutants and greenhouse gases. However, there is a current lack of adequate data on human exposure to emissions resulting from the use of ethanol-blended fuels. See link:

http://www.hc-sc.gc.ca/ewh-semt/air/out-ext/effe/ethanol/index_e.html • It is proposed in the light of the current global oil insecurity that a mandatory target

should be 5% by 2010, 10% by 2015, at least 20% by 2020 and by 2030 at least 30% of current petrol and diesel usage to power vehicles to transport people and goods be replaced with clean sustainable alternatives, including natural gas and biofuels such as ethanol and biodiesel.

• The Federal Government is urged to enact a more aggressive Renewable Fuels Standard than is currently in the legislation, noting biofuels offer an immediate alternative to imported fossil fuels, are completely compatible with current transportation infrastructure as petroleum blending components of stand-alone fuels and in the longer term, are an ideal hydrogen source for fuel cells.

• Enact legislation to use ethanol as an oxygenate in petrol and to reduce levels of

carcinogenic benzene. • Enact legislation that allows durable excise rebates for the greenhouse credits, urban

quality and health gains from ethanol and biodiesel in proportion to their proven environmental and health benefits.

• Enact legislation to require at least a prescribed percentage of vehicles transporting

people and goods to be powered by clean alternate fuels other than those based on crude oil.

• The technology exists right now to clean up these emissions from existing fossil-fuel

powered engines so that most of the adverse health impacts can be prevented or minimised. The introduction and manufacture of ‘flexi-vehicles’ capable of being powered by up to 85% ethanol should also be integral to the Federal and State Government’s biofuels policy.

• The only thing that stands between us and dramatically healthy air is the political will at

Federal and State levels to require these reductions and the funding to make them a reality.

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1. Outline of Biofuels (Ethanol & Biodiesel), Fossil Fuels and

Health Issues

1.1 Purpose: The intent of this Submission is to highlight the growing body of international and Australian scientific evidence of the risks posed to the public by traffic-related air pollution, especially coarse, fine and ultra-fine particles, gaseous irritants, and polycyclic aromatic hydrocarbons (PAH’s) that contribute to, for example: • lung cancer deaths and accelerated tumour growth; • increased cardio-vascular disease and myocardial infarcts; • limited blood flow and increased blood clotting; • increased sensitivity to bacterial products in airways, and • more severe common viral asthma. In drawing these life-threatening risks to the attention of the Economic Development and Infrastructure Committee, the author, as a matter of urgency, urges the Government to put in place clear policies in support of measures that immediately address and substantially reduce these risks to human health. This would include: • Support for the increased production, distribution and use of ethanol as a clean renewable

energy fuel; • Active replacement of toxic fossil fuels (diesel and petrol) with ethanol or ethanol-

blended petrol, liquid petroleum gas (LPG) and biodiesel, such that by 2020 at least 20% of fossil fuel (diesel and petrol) currently sold in the market place is replaced with clean re-newable fuel of which ethanol and natural gas together with LPG are the major replacements.

• Reduction of highly toxic aromatics e.g., carcinogenic benzene and PAHs in existing petrol and diesel.

A clear, non-partisan policy, in support of the expanded use of renewable and alternative fuels such as ethanol, biodiesel, and liquid petroleum gas (LPG) and compressed natural gas (CNG) would represent the introduction of known and proven measures to reduce current risks posed to human health by combustion of petrol and diesel fuels. Ethanol is particularly suitable as it is renewable and is not a carrier of toxic particles etc found in petroleum fuels such as petrol and diesel. The medium-term (within 5-years) goal must be to begin to introduce E85 as has already happened in the ethanol revolution in progressive countries abroad with the concurrent availability of ‘flexi-vehicles’. 1.2 Background: Issues of air pollution related to health impacts • Traffic-related air pollution remains a key target for public-health action overseas

including Europe, Britain, USA and India.

5 • Australia has been slow to act e.g. unlike overseas, Australia does not have health

standards for a number of pollutants derived from the combustion of fossil fuel, e.g., carcinogenic 1,3 butadiene and toxic acetaldehyde. Only recently it introduced a benzene standard (3ppb) while UK has had a benzene standard for years that is now 1ppb.

• However, the States are given jurisdiction over the interpretation and application of the

National Environment Protection Council (NEPC) air-quality standards. For example, the NEPC state that the NEPM (Measures) for PM10 do not apply to canyons between tall buildings or to point sources, yet, State Government Regulatory Authorities apply them to point sources such as pollution from tunnel stacks.

• In a major study in Austria, France and Switzerland by Kunzli et al (2000), air pollution caused 6% of total mortality or more than 40,000 attributable cases per year. Traffic pollution accounted for more than 25,000 new cases of chronic bronchitis (adults); more than 290,000 episodes of bronchitis (children); more than 0.5 million asthma attacks; and more than 16 million person-days of restricted activities.

• Toxic diesel particles account for at least 21,000 deaths annually in USA (CATF Report, Feb ’05).

• In Sydney, three-times as many people die from vehicle exhaust (up to 1,400) than die from road accidents. Cost of morbidity and mortality due to vehicle pollution in Sydney alone exceeds $1.5 billion annually (ABRE Report, 2003).

• Vehicle emissions account for up to 65 % of urban air pollution. Most of the particulate pollution is in the fine mode PM2.5 fractions that are soluble in the lungs and have PAH’s adsorbed to their surfaces.

• In most States of Australia, the toxic fine particles in the soluble PM2.5 mode are EXCEEDING the air-quality standards/guidelines set by the National Environment Protection Council (NEPC) and are generally increasing annually. See (a) NEPC (2002) Exposure Assessment Risk Characterisation for the Development of a PM2.5 Standard. (b) NEPC (2002) Impact Statement for PM2.5 Variation.

• Weight-for-weight, fine particles in fossil fuel combustion have an enormous surface area. For example, one billion 0.01 µm particles are equivalent to one PM10 (10µm) particle but have 1000-times the surface area, hence an enormous carrying capacity for their carcinogenic cargo of PAH’s.

• Alternative fuel use will continue to be driven by concerns over clean air and legislation to reduce exhaust emissions. In USA, but not yet in Australia, diesel is classified as an air toxic. Diesel exhaust poses a cancer risk that is 7.5 times higher than the combined risk from all other air toxics (CATF Report, Feb ’05).

• The risk of lung cancer for people living in urban areas is three-times that for those living in rural areas (CATF Report, Feb ’05).

• A recent Case Study (June, 2005) established that the reduction of vehicle particle pollution in Tokyo was accompanied by a significant cost-reduction in mortality and morbidity. (J. Risk Research Vol 8, p 311-329; June, 2005)

• Ethanol as a 10% addition to petrol (E10) can reduce particulates by up to a qualified 50%, more in older cars (G. Whitten) See Appendix below. Also see following links:

http://www.ethanolrfa.org/white991.html http://www.ethanolrfa.org/NEC-Whitten.pdf http://www.ethanolrfa.org/pubs.shtml See also P. Mulawa etal. Env.Sci. & Technology Vol 31 p 1302 (1997)

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1.3 Adverse impacts on health and well-being Exhaust pollution including coarse, fine and ultra-fine particles, gaseous irritants (e.g., O3 and NO2), and PAH’s either alone or in combination, are known to be associated with, for example:

• inflammatory lung diseases e.g., asthma, bronchitis and alveolitis • increased cardio-vascular disease • increased risk of myocardial infarction in susceptible persons • risk for exercise-induced heart damage • limited blood flow and increased blood clotting • increased mucous production and airway hyper-responsiveness • 1/5 lung cancer deaths (USA) and accelerated tumour growth • premature death • symptoms of anaemia e.g., tiredness, headaches, fatigue and shortness of breath. • low birth weight and small head circumference of neonate. • intra-uterine growth retardation (for each 10 nanograms PAH’s /M3 increase) • certain leukaemias e.g., from exposure to benzene. • loss in productivity, absenteeism from work and school. • Increased sensitivity to bacterial products in airways • more severe common viral asthma • reduced male fertility • significant risk of ovarian cancer from exposure to vehicle pollution • adverse effects on lung development from the age of 10 to 18 years

The effect is a major increase in sickness-care costs to the nation’s health budget. In France, a study showed 2/3 of health care costs due to pollution resulted when levels of

pollution were below the national standard for Particulate Matter (PM), less than 10 micrometre in diameter, i.e., PM10 of <50µg/M3/24 hours.

2. The Art of Perpetuating a Public Health Hazard “Denial” of a hazard by an expert, no matter how distinguished, may not imply – “the truth, the whole truth and nothing but the truth” M. Greenberg (J. Occup. & Environ. Med. 2005;Vol 47: 137-144) The current propaganda that ethanol damaging engines, has the potential to impact on food sources and potential for increased health risks (e.g., M. Jacobson, 2007) are readily refuted by objective appraisal. Claims of “no risk to health” to fumes of fossil fuel combustion seems consistent with a popular form of “denial” used by the advocates of asbestos and runs like: “We did not find the evidence for a causal association between an agent and its alleged effects” when the evidence is based on such factors as: • Unsound “negative” results derived from flawed data, methodology and study-design • Corruption of science is very common. • Concealment of data that effectively removes scientific rigour and renders reviewer powerless. • Sampling (or questionnaire) is not properly conducted in the true exposure and breathing zones.

7 • Subverting the thinking of people by the release of false information, rather than a disclosure of the true facts publicly. • Deliberately avoiding definitive answers to a number of important questions by failing to establish and operate a long-term sampling strategy for determining the qualitative and quantitative measures of hazard exposure of subjects in the study. • Keeping opinions to themselves, when confronted with the facts, allowing government or industry agents to effectively operate a policy of concealment by silence in the face of error while evidence of proven causal effects is kept confidential by agreement with management. • Early denial is given authority when made by government or industry medical officers or by some medical consultants and others, often with ‘conflicts of interest’. The significance of the hazard is down-played with a “so what?” attitude. • Claiming to adopt “world’s best practice” to imply, falsely, there are no risks to health. • Omitting significant numbers of workers (receptors) and thereby introducing a ‘negative’ bias. • Applying inappropriate standards or methods to effectively minimize the concentration of the hazardous agent in the exposure. • By initiating an ‘epidemiological survey’, as a ploy, when faced with a health problem, or to simply ignore the problem. It buys time! • Deliberately terminating studies at a stage when findings are suggestive. There have been too many studies world-wide which directly link vehicle emissions with mortality and morbidity for governments to not seriously act on the evidence. In a recent document headed, ‘Fuel Taxation Inquiry: The Air Pollution Costs of Transport in Australia’, by P.Watkiss (2002) submitted to the Federal Government, data shows that for the inner parts of Sydney (covering 2.5 million), the annual health ‘pollution’ cost is about $342,000 per tonne of particles and $1750 per tonne for oxides of nitrogen (NOx). Health cost > $3billion. It is high time lessons from asbestos, tobacco, exposure to radiation and the like are learnt! 3.1 Health advantages to using ethanol-blends • Ethanol is non-toxic, water soluble and highly biodegradable. • The American Lung Association of Metropolitan Chicago credits ethanol-blended

reformulated petrol with reducing smog-forming emission in the city by 25 % since 1990. • Ethanol reduces tailpipe carbon monoxide (CO) emissions by as much as 25 %. • Ethanol reduces particulate emissions, especially fine particulates that pose a health threat

to children, senior citizens and individuals suffering from respiratory ailments (G. Whitten, 2005). • Ethanol is an ‘oxygenate’ that permits a cleaner burn much like an open gas ring on a

Bunsen burner allows the gas to combust cleanly with a blue flame. 3.2 Benefits of ethanol-blended fuels • Many countries are adopting ethanol production to reduce harmful emissions from

vehicles and enhance economic development. • Ethanol contains 35% oxygen. Adding oxygen to fuel results in more complete fuel

combustion, reducing harmful tailpipe emissions.

8 • Ethanol also displaces the use of toxic petrol components such as benzene - a carcinogen

known to cause some forms of leukemia. • Ethanol is a renewable fuel, typically produced from plant matter. • Ethanol-blended fuels account for 18% (and rapidly growing) of all automotive fuels sold

in the United States. • Now is the time to promote ethanol in blended fuel with a banning of MTBE in USA. • Ethanol-blended fuels reduced the C02-equivalent greenhouse gas emissions by approx. 3.6 million tons in the USA in 2001. i.e., equivalent to removing 520,000 cars from roads. • Tripling the use of ethanol in USA would triple the greenhouse gas benefit. • Ethanol fuels not only enhance energy security and boost rural economies, but can reduce

harmful air pollution and greenhouse gas emissions. • Biofuels can cause a renewal in agriculture and rural Australia and benefit the entire

national economy. • Ethanol is a cheaper alternative to the escalating cost of oil and diminishing supplies that

are not meeting demand in countries such as China 3.3 What are the advantages to using ethanol-blends? • Less dependence on imported crude oil currently costing over $1 billion per month! • Extends Australia’s dwindling domestic supply of light crude petroleum used to produce

transportation fuels. • Expanded market opportunity for Australian farmers • Rural economic development • Displaces dangerous components in petrol, such as benzene • Ethanol is made from renewable resources, whereas petroleum comes from limited fossil

energy sources. • Cleaner environment (lower carbon monoxide and smog-causing emissions) • Cleaner burning engines • Improved vehicle performance. Saab Motor Manufacturer (Sweden) claims more power

is generated from its new engines designed for ethanol-blended petrol than straight petrol. • Bioethanol fuel shows better performance in reducing volatile organic chemicals (VOC),

PAH, benzene and butadiene, relative to petrol. • 10% ethanol blended petrol reduces fine particulates by up to a qualified 50%. 4. Experience with biodiesel • Emission reduction for particles, CO and gaseous hydrocarbons but increases in oxides of nitrogen (NOx). • In particulate emissions, the insoluble fraction (coarse mode) decreases while the soluble

fraction (fine mode) increases with a net reduction in total PM. The soluble fraction can be reduced by using oxidation catalysts.

• Biodegradation of biodiesel is much faster than for diesel fuel. • Studies show that, for greenhouse emissions, biofuels substantially out perform fossil

fuels (but to a lesser extent) gas fuels. • Biodiesel has significantly less ecotoxicity than diesel and ideal for sensitive rural areas. • Biodiesel fuel has a biomodal distribution of fine particles with a 30% reduction in the

0.05 and 0.1µm diameter particles, but remained the same for larger and smaller particles.

9 • Recent studies showed biodiesel can reduce emissions of particulate matter by 47% when

compared with petroleum in unmodified diesel engines. • USA EPA report verified a 67% reduction in unburned hydrocarbons and a 48%

reduction in CO2 levels with pure biodiesel (B100). Smaller reductions (12%) were obtained with 20% biodiesel and 80% petro-diesel.

5. Federal Coalition 2001 Election Policy • The Coalition undertook to promote the production, distribution and transport use of

ethanol and biodiesel, in the knowledge that it will provide new industries and jobs for rural Australia and cleaner air for our cities.

• The Federal Coalition is committed to maintain the fuel excise exemption for ethanol and biodiesel.

• The Federal Coalition also undertook to provide from 2002/03 a capital subsidy for new or expanded production infrastructure for biodiesel until total production is reached by end 2006/07.

6. Current biofuels in Australia and overseas • In Australia, biofuels with commercial prospects are ethanol and biodiesel. • Ethanol is mainly derived here from two renewable sources – fermentation from sugars in

grains such as wheat and corn and from ‘C’ molasses. • Fuel ethanol in Australia is used as a fuel blend comprising 10 % ethanol and 90 % petrol

(E-10). • Brazil is currently the largest producer of ethanol at more than 12-15 billion litres per

annum. In 2005/06 ethanol production was over 16.8 billion litres. • The U.S. produces 10 billion litres per year, with production expected to rise to 19 billion

by 2012. • Overseas ethanol-blended fuels may contain as much as 85% ethanol. Car manufacturers

Saab, Chrysler, Mazda and Ford are now marketing cars to compute automatically to any alcohol-blended fuel.

• Biodiesel is derived from treatment of vegetable oil or animal fats. • Canola oil is our principal oil seed and is harvested in November and December. • Biofuels, unlike fossil fuels, are climate and rainfall dependent. • The European Union in 2001 introduced a proposal to promote biofuels such as biodiesel,

bioethanol or hydrogen fuels. The Commission’s goal is to increase biofuel use from 2% in 2005 to 5.75% in 2010 and 20% by 2020.

• Approximately 8% of diesel fuel sold in Germany is biodiesel. • Australia’s Federal Coalition in October 2001 made a commitment to promote the use of

biofuels such as ethanol and biodiesel to ensure biofuels provide 2% of our transport consumption by 2010.

• More recently, it is evident that the Federal Government had become seduced by misinformation propagated by lobbyists and through the media by powerful invested interests and their associated ‘dirt teams’ coupled with flawed scientific commissioned reports.

• Fuel ethanol production and use is also being promoted in China, India, Thailand and Japan.

• The NZ Government in February, 2007 announced that from April, 2008 a mandated minimum level of 3.4% of total fuel sold by oil companies to be biofuel (bioethanol and biodiesel) by 2012.

10 7. Issues 7.1 Energy Security 1. The global production of crude petroleum in 2005 was approximately 80 million barrels

per day, or 29 billion barrels annually. Continued production at this level, based on total global reserves of one trillion barrels, and without any increase to accommodate increasing annual demand, would mean that global oil reserves equate to approximately thirty five years supply.

General consensus asserts that crude petroleum is a finite resource, and global reserves are

limited, compounded by a time when demand for crude petroleum starts to outstrip supply.

2. Coupled with this is the problem of spare capacity. In crude oil production terms, spare capacity is pumping capacity that is currently unused but can be turned on immediately if needed in a crisis. The days of spare capacity in the global crude petroleum industry are gone. What this means is that should global crises arise (natural disasters e.g., Katrina hurricane, or wars in oil-producing countries such as Iraq and Iran) supply will barely if at all keep up with rising demand.

It is highly significant that the USA war on Iraq was launched on the false allegation that

Iraq had ‘weapons of mass destruction’. Similarly, the current posturing by USA toward Iran is based on a pretext that Iran has or is planning to develop ‘nuclear weapons’. But no war is ever prompted by one factor alone. Oil played a role in USA decision to invade Iraq. Similarly, Iran has immense oil and natural gas reserves and will have a critical role in the world’s future energy equation. However, major USA energy companies are prohibited from working with Iran by Executive Order, signed by President Clinton in 1995 and renewed by President Bush in 2004.

The truth is the current government of Iran has plans (as did former President Saddam of Iraq) to set up an OIL BOURSE i.e., an oil trading market based on the petroeuro rather than the current petrodollar. This poses a threat to USA’s economic supremacy and to London’s International Petroleum Exchange and Nymex in New York. Current membership of the proposed Iran Oil Bourse includes Russia, China and India. Iran had plans to open the Oil Bourse in March, 2006. Already Iran is trading in petroeuros! Tehran has the only military in the region that can threaten its neighbours (including Israel) and Gulf security. Thus, while publicly focusing on Iran’s ‘weapons of mass destruction’, powerful western governments, led by USA, are thinking in geopolitical terms about Iran’s role in the global energy equation and its capacity to obstruct the global flow of petroleum e.g., through the Strait of Hormuz. However, the economic threat of an Oil Bourse to the global economic supremacy of the USA is clearly the principal reason the USA will attack Iran and likely via an ‘anti-nuclear’ strike by Israel. The sabotage of local oil fields will exact a high price to economies of the Western World. See following commentaries:

Peak Oil Australia http://www.peakoil.org.au/news/index.php?isa.review.htm Can 'Axis of Crude Oil' topple US Dollar? (May, 07)

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http://www.garnertedarmstrong.ws/Mark_Wordfroms/IranianOil1/newstory-051.shtml Iran oil in euros (Jan 07) http://www.garnertedarmstrong.ws/Mark_Wordfroms/IranianOil1/newstory-048.shtml Summary of events on Iran's Oil Bourse: http://www.garnertedarmstrong.ws/Mark_Wordfroms/manews0054-news_stories3.shtml Assault on Iran gains support: (17.7.07) http://www.smh.com.au/news/world/assault-on-iran-regains-support-in-white house/2007/07/16/1184559704090.html Read here: http://www.debka.com/ about Iran getting long distance bombers.

7.2 The Situation in Australia 1.Geosciences have noted that Australia’s consumption of crude oil and condensate in 2004

could be sustained by remaining economic reserves for only 9.3 years. These figures paint an alarming picture.

2.They suggest that Australia’s appetite for petroleum products is rapidly outstripping our

indigenous production sources. This equates to a remorseless increase in Australia’s dependence on the highly volatile and insecure international crude oil market.

7.3 Implications for Australia The implications for Australia are simple, and alarming. As a country very highly dependent on road transport for the movement of both goods and people, and as a country currently committed almost entirely to the use of products derived from crude oil to fuel that transport, Australia is in a position of great vulnerability. This is exacerbated by the fact that Australia’s indigenous reserves of crude petroleum are lower than the global average, and the rundown of Australia’s oil reserves is occurring at a faster rate than the global average. Thus, Australia needs an urgent shift to policy settings to shift in demand from conventional fuels such as petrol and diesel to more sustainable alternatives, and thereby trigger commercially and socially viable outcomes. 8. Petroleum-based transportation fuels– the biggest polluter

• U.S Environment Protection Agency (EPA) claims gasoline is the largest source of man-made carcinogens.

• In USA, deaths from effects of air pollution exceed those of breast and prostate cancer

combined.

• Deaths from air pollution exceed those from traffic accidents. Petroleum-based transportation fuels – the biggest polluter. WHY?

12 “Oil and car industries have acted again and again to deceive regulators about the hazards of their products and have used their wealth to hamstring attempts by state and federal legislators to make laws that address such threats.” “The corporate philosophy of these industries has prevented consumers from buying safer, cleaner, more sustainable fuels and transport choices. That has stunted the biofuels industries.”

Terry Tamminen ‘Lives per Gallon’ (2006)

Anti-trust Conspiracy Unlawful restraint on the development and marketing of alternative cars and fuels - the competitive market has suffered as a result. “The oil and car companies have stalled the introduction of cleaner-petroleum vehicles by fighting fuel economy standards, and hindered the introduction of alternative fuel cars by misleading regulators and consumers e.g., by zealously lobbying lawmakers against mandates to offer these products to the public and have deceived lawmakers, regulators and the public about the technology, utility, and cost of such alternatives.”

Terry Tamminen ‘Lives per Gallon’ (2006) 9. Problems of Diesel

• Complex engineering • Environmental • Medical / biological • Legal • Management • Public health • Ethical • Public administration and good government • Fairness and justice - those most harmed are

those least able to defend themselves - children of the urban poor. 10. The Risk-Based Approach to Diesel and Petrol The principle is to adopt “business as usual.”

• Has backing of powerful special-interest groups harnessing governments to deflect and stymie the search for least harmful alternatives. This includes not only the oil cartels but also to some extent, through patronage, by self-interested groups and organizations whose commissioned reports have, in some instances, been demonstrably biased and scientifically flawed. Patronage is very much the life-blood of politics and government funding!

• So long as the exact size of the problem is uncertain, risk assessors call for delay and more study. Research funding for some is a survival strategy where the aim in some cases is not to solve a problem but to create others. It all helps to maintain viability, personal and professional development, but often without a social conscience. • Because consultants can commonly be ‘bought’ or ‘hired’ to reinterpret old data to

13 cast doubt on the nature of the problem, action can be stalled for decades.

• Doubt is a powerful helpmate when your goal is to maintain “business as usual.” • The risk-based approach waits for the holy grail of scientific certainty to emerge from the data, meanwhile do nothing.

11. Why is the ‘Precautionary Approach’ not taken?

• Because the risk-based approach to public health continues to be adopted i.e., wait until the dead bodies can be counted. • Whilst petrol and diesel fumes are known to cause lung cancer, health bureaucrats state they are “not yet sure” how big the problem is and “we have not identified the extent of the problem.”

This is the classic risk-based approach. Ignore the evidence so long as it is not 100% watertight. Use uncertainty as an excuse to delay. Wait for the dead bodies to pile, then slowly acknowledge the need for action. Precaution is not (yet) fashionable – Risk-assessment is ! 12. Assistance needed • Assistance is needed in the general development of the biofuel industry. This includes

new storages, crushers, refineries and associated infrastructure. • Need to legislate fuel standards to include renewable biofuels such as biodiesel and

ethanol-blended petrol. • Address the escalating costs of growing crops e.g., canola, grains and sugar-cane,

because of enormous amounts of inputs, disease levels and diminished yields giving unprofitable returns.

• There is an urgent need to increase farmer confidence for canola, grains and sugar cane. • Long-term excise relief (or domestic producers credit) is required to engender confidence that lenders will have debts/loans re-paid. • Capital subsidy be provided for enhanced ethanol production to attract investment capital

from prospective owners. 13. Action Points for Development and Consensus 13.1 Incentives to increase ethanol production Incentives for production facilities

• The petroleum industry, in this country, MUST recognise that ethanol is a reliable component in meeting consumer demand for clean, affordable fuel.

• In the USA 30% of petrol sold is blended with ethanol. In all of Australia the goal, over the next 5 years, is to achieve 350 million litres of biofuel (biodiesel and ethanol) i.e., less than 2% of fossil fuel sold in the market place. This highlights the humbug recommendations of the Biofuels Taskforce (2005) and underscores the Australian impediments to ethanol production that must be identified and rooted out.

• Assistance is needed in the general development of the biofuel industry. This includes new storages, crushers, refineries and associated infrastructure.

• Need to legislate fuel standards to include renewable biofuels such as biodiesel and ethanol-blended petrol.

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• Address the escalating costs of growing crops e.g., canola, grains and sugar-cane, because of enormous amounts of inputs, disease levels and diminished yields giving unprofitable returns.

• There is an urgent need to increase farmer confidence for canola, grains and sugar cane.

• Long-term excise relief (or domestic producers credit) is required to engender confidence that lenders will have debts/loans re-paid.

• Capital subsidy be provided for enhanced ethanol production to attract investment capital from prospective owners.

• Establish farmer cooperatives (overseas model) to manage grain production and distribution as well as ownership of new ethanol producing facilities

• One of the most important ways to make sure the rural economy is strong is to promote value-added processing, like ethanol production. The dramatic expansion of ethanol production in the USA has been spearheaded by farmer-owned ethanol plants. By 2003, 32 of the 72 ethanol plants across USA were farmer owned. These plants create thousands of new jobs while raising profits for all farmers. Victoria must develop the knowledge and skills to implement such ventures.

• By working together, we can create a strong rural economy and reduce our country’s dependence on imported energy supplies.

• Establish an expanded Renewable Fuels Association (RFA or equivalent) that provides technically accurate and timely information to the auto manufacturers, and technicians, the media, the policy makers, marketers, refiners and the general public.

• Provide ‘RFA members’ with the information for informed business decisions.

13.2 Incentives to increase ethanol distribution Incentives for service station conversion to ethanol • Legislate for the removal of all negative signs and labels referring to ‘ethanol’. • This must be integral with strong Federal and State support of Renewable Fuels as

part of a national energy bill. Enacting these forward looking policies will keep the ethanol expansion growing strong. Incentives for blending and distribution facilities • Appoint an ‘Independent Watchdog Board’ to oversee probity issues in ‘fair trading’

in the availability, supply and cost of petrol for blending. • An adequate ethanol distribution system must be developed without being stalled by

the bureaucratic incompetency’s and impediments that characterize the current State Regulatory Authorities.

• Adequate stocks of ethanol must be in place. • Distribution terminals (where appropriate) must be retrofitted (with financial

assistance and/or tax incentives) to accommodate ethanol delivery, storage and blending.

• Adequate stocks of reformulated blendstock for ethanol blending must be produced and distributed.

Incentives for the establishment of terminals and depots • Must keep bureaucrats out and limit oil-industry monopoly. Incentives needed by way

of tax concessions for construction and or retrofitting.

15 Targets and timeframes of service stations with the capacity to supply E10 ethanol by

2010 • Need a broad integrated strategy to include the introduction of E85 and flexi-

vehicles with a timeline. 13.3 Incentives to increase demand for ethanol

Mandate E10 • For comparison, Brazil already requires 25% ethanol in petrol. The success of the

ethanol industry in Brazil and USA has been dependent upon mandating. Australia’s Federal Government has foolishly opted to patronize the Oil Cartels in the naïve belief that a ‘gentleman’s agreement’ will suffice to meet the ethanol goals. To address the current political dickering with the Oil Cartels, Victoria should implement a mandate for E10 in the first instance to make it obligatory for the Oil Cartels to comply with such legislation, requiring E10 to be made available at the pump, by law.

Incentives to convert cars to E85 • Similar incentives as currently being offered by the Federal Government to convert

cars to E10 or LPG. • Free parking in the city because of very low pollution from E85, similar to what is

offered in Sweden to motorists who purchase a Saab 9-5 E85.

Motor vehicle registration concessions • Remember the cost of health impacts in Sydney alone from vehicle pollution from the

combustion of fossil fuels is over $2 billion dollars annually. This is the classic method of the corporate stakeholder augmenting profit by passing health costs to the community. An incentive for motorists would be to reduce costs of registration to clean fuel users and levy the oil companies a ‘health-cost tax’ on their profits.

13.4 Initiatives to promote ethanol

Marketing and education campaign Promote Federal, State and Local Government policies, programs and initiatives that

encourage expanded use of ethanol. At the same time expose the alleged insidious counter-practices of the Oil Cartels.

• The synergy derived from blending ethanol with petrol goes far beyond expanding petrol supplies. Ethanol provides a major boost to rural economies and farmer income. Ethanol reduces our dependence on dwindling foreign oil supplies. Ethanol use reduces harmful vehicle emissions, ozone pollution and greenhouse gas-forming emissions.

• Ethanol use protects the air we breathe and the water we drink. E10 containing 35% oxygen by weight, ethanol improves the combustion of petroleum fuels, thereby reducing harmful tailpipe emissions and ozone-forming pollutants. At the same time, being highly biodegradable, ethanol does not provide a threat to waterways as do some other petrol additives.

• Ethanol blends reduce CO and hydrocarbons by 20% and fine particulates by 50% by gross polluters (older vehicles or cars with malfunctioning pollution control devices).

• Ethanol is renewable because it is about harvesting the power of the sun’s energy • Utilizing the solar energy stored in plants, ethanol maintains a positive fossil energy

balance. Ethanol yields 134% of the energy used to grow and harvest the crop, and

16 process it into ethanol. By comparison petrol yields only 80% of that used to produce it. • In 2003, ethanol use in the USA reduced CO2- equivalent greenhouse gas emissions

by approx 5.7 million tons equal to removing the annual emissions of more than 853,000 cars from the road.

• Cellulosic ethanol could have an even larger impact. • Ethanol plants produce other high-quality co-products including high-value live-stock

feed or distiller’s grains. • Using home-grown ethanol keeps our energy dollars home, thereby stimulating our

economy, creating jobs and reducing our trade deficit. The current flood of foreign crude imposes an economic penalty of enormous proportions for our country that is not reflected in the price we pay at the pump. It is a penalty that costs jobs and drains investment capital etc.

• Blending ethanol with petrol stretches our fuel supplies and reduces the amount of oil we need by tens of thousands of barrels each day

Appoint an ethanol ambassador • The success in the USA for example, continues to be immensely helped by the

establishment of a properly constituted Renewable Fuels Association (RFA) in 1981 as the national trade association for the US ethanol fuel industry. The RFA serves as a vital link between the ethanol industry and the Federal, State and Local Governments as well as other stakeholders and interest groups to promote increased production and use of ethanol through supportive policies, regulations and research & development initiatives. By adopting such a template in Australia, an ethanol ambassador could be identified in Victoria. Already a fledgling ‘RFA’ has arisen in Australia along with other groups but need to be formally constituted with the appropriate membership and financial structures in place to emulate the US counterpart for nationwide recognition.

• Such an organisation would host an Annual Ethanol Conference to bring together national and overseas stakeholders to share experiences in production, marketing and policy.

Possible monitoring and compliance measures • There needs to be in place not only the statutory control mechanisms but a separate,

independent, identifiable, highly professional and effective organisation (similar to the USA RFA) dedicated to the continued vitality and growth of ethanol in the fuel marketplace.

14. Comments regarding the current CSIRO/Orbital Study of E5

and E10 vs Health Impact 1. Alleged flawed assumptions a) The study wrongly assumes that E5 and E10 are alternative clean fuels. Ethanol at 5% and 10% in unleaded petrol (ULP) is only an OXYGENATE ADDITIVE. The alternative fuel is E85 with ethanol representing 85% added to 15% ULP. Therefore, ULP should be compared to E85 as a clean alternative fuel, not E5 and E10.

17 All petrol vehicles are capable of operating on petrol/ethanol blends with up to 10% ethanol (gasohol). In fact, some states in USA require the seasonal or year-round use of up to 10% ethanol as an oxygenate additive to petrol to help mitigate ozone formation. These low percentage oxygenate blends are not classified as alternative fuels. We should speak of ethanol vehicles as those specifically manufactured to be capable of running on up to 85% denatured ethanol, 15% petrol (E85), or any mixture of the two up to the 85% ethanol limit. E85 may be seasonally adjusted in colder climates such that the real proportion of E85 is less than 85% ethanol. Gasohol is considered to have positive environmental effects. Studies show, depending on a range of experimental conditions, that using gasohol, instead of regular petrol, reduces carbon monoxide (CO) emissions by as much as 17-26.9 per cent, carbon dioxide (CO2) emissions by 4.2 per cent, and hydrocarbon emissions by 5 per cent. Furthermore, using gasohol also reduces emissions of benzene (a known carcinogen) and 1,3 butadiene (also a known carcinogen). The downside of gasohol use can, under certain conditions, be increased emissions of nitrogen oxides (NOx), volatile organic compounds (VOCs), and aldehydes. The degree to which emissions increase depends on the vehicle and emission control technology used. Some reports claim E10 leads to a 14.4% reduction in non-methane VOCs. The Environmental Choice Program of Environment Canada grants certain products the right to use the EcoLogo trademark. This trademark identifies products that help reduce the burden on our environment. Ethanol-blended petrol has been approved to carry this trademark. The emission impacts of pure ethanol and E85 have been rigorously tested by the EPA and Department of Energy, and numerous other public and private research entities. The results of these tests have clearly indicated ethanol has a superior emissions profile and health record when compared to petrol.

The expectation is that CSIRO will confirm the results of such studies using E5 and E10 as oxygenates, but not as an ‘alternative clean fuel’.

b) The CSIRO draws attention mainly to NO2, as the major cause of ozone pollution, but excludes CO.

To exclude CO appears to show a high degree of bias. There is no nitrogen (N) in ethanol (C2H5OH) which is not a fossil fuel. The main source of NOx is from the air and fossil fuel (unleaded petrol) to which E5 and E10 are added as oxygenates to give a ‘cleaner burn’. About 70% of NOx in the atmosphere comes from vehicles powered by fossil fuel. See link:

http://www.pmc.gov.au/biofuels/submissions/submission27.doc

Note the following at the link:

http://en.wikipedia.org/wiki/Tropospheric_ozone

The majority of tropospheric ozone formation occurs when nitrogen oxides (NOx), carbon monoxide (CO) and volatile organic compounds (VOCs), such as xylene, react in the atmosphere in the presence of sunlight. NOx and VOCs are called ozone precursors. Motor vehicle exhaust, industrial emissions, and chemical solvents are the major anthropogenic sources of these chemicals. Although these precursors often originate in urban areas, winds can carry NOx hundreds of kilometers, causing ozone formation to occur in less populated regions as well. Methane, a VOC whose atmospheric concentration has increased tremendously during the last century, contributes to ozone formation but on a global scale rather than in local or regional photochemical smog episodes. In situations where this exclusion of methane from the VOC group of substances is not obvious, the term Non-Methane VOC (NMVOC) is often used.

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The chemical reactions involved in tropospheric ozone formation are a series of complex cycles in which CO and VOCs are oxidised to water vapour and carbon dioxide. The reactions involved in this process are illustrated here with CO but similar reactions occur for VOC as well. Oxidation begins with the reaction of CO with the hydroxyl radical. The hydrogen atom formed by this reacts rapidly with oxygen to give a peroxy radical HO2

OH + CO → H + CO2 H + O2 → HO2

Peroxy radicals then go on to react with NO to give NO2 which is photolysed to give atomic oxygen and through reaction with oxygen a molecule of ozone:

HO2 + NO → OH + NO2 NO2 + hν → NO + O O + O2 → O3

Thus, CSIRO seems to exclude CO in the formation of smog. Is CSIRO exploiting the claims that under certain circumstances, E10 can increase NO2 in the combustion gases and hence can conditionally contribute to smog but ignores the positive contributions made by reduced CO?

Variables such as heavy acceleration can also vary these tail-pipe outcomes that the CSIRO Protocol appears not to include. Note that the Australian Institute of Petroleum (AIP) states as follows:

http://www.pmc.gov.au/biofuels/submissions/submission27.doc

The effect of E10 blend petrol on NOx emissions is very dependent on vehicle technology. However, the general effect of E10 is zero to a small increase in NOx emissions. In Australia, the Orbital study found that, for ethanol blends under 12 %, NOx emissions were virtually unchanged from those of the base petrol. The APACE 1998 study found an average 1% increase in NOx. In summary, introduction of an E10 blend petrol would not be expected to have a significant effect on motor vehicle NOx tailpipe emissions. The overall levels of motor vehicle NOx tailpipe emissions are modelled to further reduce from the levels applying in 2000, by 40% by 2010, and by 60% by 2020 as a result of the introduction of tighter fuel standards and vehicle ADRs.

Already published work has established that ethanol-blended petrol has a ‘neutral’ effect in contributing to ozone because any qualified increases in NOx are balanced by decreases in CO and VOC’s. Therefore, the CSIRO/ Orbital Study is expected to confirm these previous findings, provided CSIRO incorporates CO in its analysis.

According to the American Lung Association, E85 is cleaner and credits ethanol with reducing smog formation in Chigago by 25% and ozone by 20%. Ethanol is less toxic. Use of E85 reduces the release of toxic chemicals such as benzene, toluene and xylene.

Here is a strong case for the CSIRO Protocol to have validation by outside, preferably overseas reviewers, not internal ‘CSIRO peer-reviewers’.

c) CSIRO’s argument seems that if E5 and E10 do not reduce toxic emissions it is inferred the fault rests with ethanol in not reducing health impacts.

The problem with E5 and E10 is that the bulk of the fuel is highly toxic petrol which is the source of ALL the PAHs and the vast majority of toxic VOCs. Common sense says that if a clean renewable fuel is to be compared with petrol then E85 is the ethanol blend that should be tested. This study from the beginning is one that has a pre-determined methology to guarantee a negative finding generally.

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Both methanol and ethanol evaporate more slowly than gasoline, thus helping to reduce evaporative emissions of volatile organic compounds (VOCs), which react with heat and sunlight to generate ground-level ozone (a component of smog). According to Environmental Protection Agency estimates, in cars specifically designed to burn pure methanol or ethanol, VOC emissions from the tailpipe could be reduced 85 to 95 percent, while carbon monoxide emissions could be reduced 30 to 90 percent. However, emissions of nitrogen oxides, a source of acid precipitation, would not change significantly compared to petrol-powered vehicles. So why is E85 excluded from the CSIRO Protocol?

California Environmental Policy Council (CEPC) study in 1999 concluded that while ethanol may slightly increase levels of acetaldehyde and PAN, these compounds are more than offset by reductions in formaldehyde. CEPC also concluded that other compounds found in petrol, such as aromatic compounds and olefins, are primarily responsible for the formation of formaldehyde, acetaldehyde and PAN due to their greater abundance in petrol.

A 1997 study on the emissions of ethanol-blended reformulated petrol in the Denver, Colorado, area reported that the concentrations of formaldehyde and acetaldehyde during the winter of 1995/96, when nearly all the fuel was blended with ethanol, were not significantly different from those measured during the winter for 1988/89 when 95% of the fuel was blended with MTBE. (Anderson L.G., J.A. Lanning, E. Wilkes, P. Wolfe, and R.H. Jones. "Effects of Using Oxygenated Fuels of Carbon Monoxide, Formaldehyde and Acetaldehyde Concentrations in Denver," Paper 97, RP139.05, Air & Waste Management Association).

d) VOC evaporative emissions study involving E5 and E10 seems biased, without E85

The fact is that there is already an ENORMOUS evaporative impact from petrol, especially at the pump and known to impact adversely especially on children putting them at a higher risk of leukaemia. In some overseas countries vacuum fans draw off the toxic fumes during filling of the petrol tank. Biofuels (ethanol and biodiesel) currently represent less than 1% of fossil fuel sold in the market place.

Where then is the voice of CSIRO in highlighting the hazard of evaporative petrol alone and recommending such a preventive measure here? Rather, it seems, for political and organizational expediency, the protocol, with its pre-determined methodology, is about embarking on a somewhat mischievous campaign to show what is already known i.e., that non-toxic ethanol when added to highly toxic petrol can increase the evaporation of the E5 and E10 blends. The solution is to use E85 and reduce or eliminate the petrol and its highly toxic additives, such as benzene. The villain is petrol not ethanol. One wonders what CSIRO will ‘find’.

As already established, the low ethanol blends E5 and E10 used predominantly today have higher evaporative emissions in warmer climates. It is well documented that the best way to mitigate against that is to use ethanol in high blends such as E85. If indeed CSIRO was really serious about reducing the health impacts of fossil fuel one would have expected E85 to be included in its comparative fuels, along with E5 and E10. More importantly one would have expected CSIRO to show a commitment to this end by supporting a transition to really using ethanol as a clean alternative fuel (E85) as opposed to just a fuel additive!

Noteworthy are the comments of AIP. See link:

http://www.pmc.gov.au/biofuels/submissions/submission27.doc

Extracted as follows:

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When ethanol is blended with petrol, there are converse effects on VOC emissions between exhaust tailpipe emissions and evaporative emissions:

• Exhaust tailpipe emissions will be reduced. The effect of ethanol is to ‘lean’ the fuel mixture in older vehicles (primarily those with carburettors), and so reduce tailpipe VOC emissions. Orbital found reductions of 14% with ethanol blends under 12%. Similar results have been shown in overseas studies; internal testing by BP in Germany on E5 blends showed a reduction of 10%.

• Evaporative emissions will increase, due to two factors, increased vapour pressure of the

blend, and increased permeation of elastomers in the fuel systems o Ethanol has a higher vapour pressure than petrol (typical values are 130 RVP for

ethanol compared to 70 RVP for petrol). This increases the potential for fugitive vapours of VOCs.

o Ethanol increases the release of VOC vapours through the permeation of elastomers

in fuel systems. A recent US study prepared by the Air Resources Board and Coordinating Research Council for the Californian Environment Protection Agency, Fuel Permeation from Automotive Systems (CRC-65), found that ethanol significantly increased evaporative emissions through permeation through elastomers by an average of 45%.

• The composition of the VOC changes. With E10 blends, there is a reduction in the tailpipe

emissions of the air toxics toluene and xylene but an increase in the emission of the air toxics acetaldehyde and formaldehyde.

• The overall effect of an E10 blend will be to increase emissions of VOCs. The CRC-65 study

found that the increase in evaporative emissions more than offset the slight reduction in tail pipe emissions. Another US study, by the National Research Council, Ozone-forming Potential of Reformulated Gasoline also found that ‘the increase in evaporative emissions from ethanol containing fuels was significantly larger than the slight benefit obtained from lowering the CO exhaust emissions using ethanol containing fuels.’ The report concluded that the use of oxygenates such as ethanol and MTBE in reformulated gasoline had little impact on air quality and some disadvantages.

Overall, emissions of HCs / VOCs are a significant air quality management issue. The level of motor vehicle HC emissions are expected to reduce with the mandated introduction of tighter fuel standards and vehicle ADRs, combined with controls on summer petrol vapour pressure and vapour recovery systems. The introduction of E10 blends has both positive and negative effects on emissions of VOCs, however the overall effect will be to significantly increase emissions of VOCs.

CSIRO is essentially repeating this work, but fails to differentiate between the claimed “positive and negative effects”of E10. The bias in the CSIRO study is evident by its EXCLUSION of the benefits of E85, by omitting E85 from the CSIRO Protocol.

e) Risk assessment is largely an art-form rather than a science

The determination by CSIRO/Orbital of ‘health impact’ by E5 and E10 appears not to adopt the recommended processes.

Risk assessment has been defined by the following four steps:

21Step 1: Hazard identification.

Hazard identification involves estimating chemical risks for acute (single dose), subchronic (a few doses), or chronic exposures for each possible toxic endpoint, such as liver damage or birth defects, or immune system damage, or central nervous system damage, or reproductive system damage, or cancer, and any other such "endpoint". There are no safe levels for benzene and particles. Hazard identification in the CSIRO Protocol seems poorly defined or not at all.

Step 2: Dose-response assessment.

Dose-response assessment usually includes extrapolation from high doses to low doses. Dose-response assessment means determining what damage, and to which bodily systems, will occur as the dose of a chemical increases. This is not apparent from the CSIRO Protocol.

Step 3: Exposure assessment.

Exposure assessment attempts [or should attempt] to determine how much of a chemical (or of all similar chemicals) is absorbed from all sources. Example: if the chemical is a VOC, exposures might occur through food, groundwater, air, and through home and occupational uses. Exposure assessment appears not clearly defined in the CSIRO Protocol.

Step 4: Risk characterization.

This final step in a risk assessment uses data from the three previous steps to make decisions regarding individual and population risks, blending the previous steps with information about the characteristics of the exposed population to describe the potential adverse outcomes and to describe the strength [validity] of both the evidence and the extrapolations. In other words, risk characterization takes information from hazard assessment, dose-response assessment, and exposure assessment, then adds information about the characteristics of the affected population -- How old are they? Do they eat a lot of fish? Are they generally malnourished or overweight? -- and combines it all together to determine an estimate of risk, usually expressed as a probability of a particular kind of harm over a specified period of time. For example, a typical estimate of risk might be expressed this way: a particular group of people is expected to endure one additional cancer for every 10,000 people, over and above the normal risk of cancer, as a result of chronic exposure to some toxic chemical in the atmosphere during their lifetime of 70 years.

There is no clear evidence in the CSIRO Protocol that these steps are being applied, either alone or together.

Highlights of major shortcomings of risk assessment apparently not taken into account in the CSIRO Protocol

Risk assessment is not really a science; it is an art that weaves together various strands of information, some of which have been gathered by scientific methods. Risk assessment is "an evolving art based on sound scientific principles and judgments...." But "judgments" are not scientific because they are not reproducible from one laboratory to another; different risk assessors will make different judgments when faced with the same data (or the same lack of data). Thus CSIRO will arrive at different conclusions to those of a separate independent research organization depending on various factors.

Yet risk assessment is routinely characterized in the media and elsewhere as a scientific enterprise -- a characterization that is misleading at best, and intentionally deceptive at worst.

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Different risk assessors will reach different conclusions because risk assessments are completed using differing techniques. As with the CSIRO Protocol, not all considerations in risk assessment are specified in any one set of laws or procedural manuals; many are built upon training and experience of the toxicologists who assess the risk. Thus there may be significant variations in the conduct and results of risk assessments. Here we see again that risk assessment is not a science, but an art.

Risk assessment has traditionally emphasized the carcinogenicity of chemicals. This appears omitted in the CSIRO Protocol since many proven carcinogens fall in the PAH group (mainly on fine particles) but PAHs are NOT being measured in the original CSIRO Protocol. There are many kinds of harm that chemicals can cause besides cancer. A risk assessment needs to consider neurological damage; damage to the immune system and the endocrine system; developmental damage; reproductive damage; and genetic damage. This appears absent in the CSIRO Protocol.

Developmental effects are also intensively investigated, because a single exposure during a sensitive period in gestation can have lifelong detrimental effects. Exposure to as little as 15ngm PAHs/ cubic metre of polluted atmosphere can detrimentally affect the developing fetus. Preventing exposure to mutagens (chemicals that cause inheritable genetic changes) is important for the same reason. In other words, a single exposure to a toxic chemical at the "wrong time" during development can cause permanent damage to a fetus or a young animal or child.

There will always be aspects of the toxicity of a chemical that are not known, so "uncertainty factors" should be applied to try to protect public health from unknown hazards. The total uncertainty factor used may thus vary from 10 to 10,000, depending on the available data; the most common value is 100. Some uncertainty may remain unquantifiable. If uncertainties cannot be quantified, then one cannot know whether a safety factor of 10 or 100 or 1000 is "adequate" to protect public health and safety. One can guess and hope, but guesswork and hope are not science -- they belong in the realm of art or personal philosophy.

The effects of multiple exposures cannot be known: Because of the near-infinite number of potential mixtures, it is impossible to experimentally test for all interactions, and relevant studies of an effect or interaction are not usually available. So risk assessors study the effects of one chemical at a time, as if people and animals were never exposed to multiple chemicals simultaneously. This is a major flaw in decision-making that is based upon risk assessment. In the real world, people are exposed to multiple chemicals all the time -- prescription drugs, cigarette smoke, automobile exhaust, multiple pesticides, food additives, indoor air pollution from building materials, carpets, and so on.

The likelihood of nervous system damage cannot be reliably evaluated because there is no standard way to test for it: Dozens of procedures to analyze various nervous system functions have been developed over the last few decades to evaluate both acute and chronic effects of chemicals, but no comprehensive test battery has emerged as a standard. Information on neurotoxicity for most environmentally significant chemicals is therefore fragmented and difficult to interpret, and there are no simple guidelines for use of the data in risk assessment.

The likelihood of damage to the immune system cannot be reliably evaluated because no single test is adequate to measure the immunologic effects of chemicals on those multiple system components. Where data do exist, the meaning of the data is not clear: Human data concerning chemically induced modulations [modifications] of immune-response parameters are scarce. Where modulations have been observed, the biological significance has been unclear.

Furthermore, immune system toxicity data are truly scarce: To date, little immunotoxicity information is available for environmental chemicals. In the US EPA Integrated Risk Information System (IRIS), which provides summary toxicity data on over 200 chemicals, only one chemical has a reference dose based on immunotoxicity. There are over 60,000 chemicals currently in commercial use, so having

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'safe' doses established for only one chemical based on immune system toxicity gives an indication of how far we have to go.

Toxicity to human genes is important, but difficult to assess. Developmental effects are also intensively investigated, because a single exposure during a sensitive period in gestation can have lifelong detrimental effects. Preventing exposure to mutagens is important for the same reason.

It has been estimated that among all congenital effects [birth defects] about 20% have environmental causes. In other words, environmental factors alone cause 20% of all birth defects. There are about 4 million live births each year in the U.S., so there are between 200,000 and 400,000 serious birth defects each year. Of these, 40,000 to 80,000 are caused by environmental influences and not by inherited genetic problems.

In addition to problems that are severe enough to be recognized as birth defects, genetic changes can lead to more subtle results: a child may lead a less healthy life, be more susceptible to disease, or have a shortened productivity and life span.

There is no way to quantify such subtle effects, and no way to avoid them except by eliminating exposures to genotoxic chemicals. Risk assessment thus gives a false sense of security.

But genotoxic chemicals are very difficult to identify: A major problem in hazard identification is to determine the relevance to human health of the hundreds of available genotoxicity assays [tests].

Therefore, it seems proper to conclude that testing of chemicals for genotoxicity is very important, but cannot be done at present, and is unlikely to be done in the near future.

Furthermore, it is known that some chemicals can harm the nervous system, but risk assessors have no standard way to evaluate chemicals for such damage.

Also, some chemicals can harm the immune system, but risk assessors have no standard way to evaluate chemicals for such damage.

It is known that humans are exposed to multiple chemicals simultaneously, but risk assessors have no way to evaluate the effects of several chemicals simultaneously.

Evidence confirms that developmental toxicants, reproductive toxicants, and genetic toxicants are all non-threshold chemicals. Carcinogens are also considered to be non-threshold chemicals. For these classes of hazardous chemicals, the only safe dose is zero, which means we must prevent exposures not rationalize and justify them via risk assessment.

The author has never seen a risk assessment that conforms to these guidelines. For example, a risk assessment seems never actually to take into account the particular characteristics of an exposed population; but rather "averages" are used, not particulars. Therefore, though risk assessment is defined as a thorough investigation, in my experience, the "rules" for carrying out risk assessments are seldom observed as is the alleged case with the CSIRO Protocol.

In sum, risk assessment is not a technique that can protect the public from toxic chemicals. Instead, it is a technique that gives the public a false sense of security, while allowing health damage to occur. People, including scientists, who claim to be able to determine 'safe' doses of chemicals based on risk assessment techniques are deceiving themselves and -- worse -- misleading the public. The CSIRO Protocol acknowledges that toxics e.g., formaldehyde and acetaldehyde can be present in E5 and E10 but its Protocol is focused on whether the addition of non-toxic ethanol affects the toxics of petrol.

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CSIRO would gain greater credibility to campaign against the toxicity of petrol alone by promoting E85.

f) CSIRO Protocol fails to acknowledge that current National air quality standards e.g. NEPM, allow disease.

Extensive medical studies have shown that human illness can result from particles in the air at levels that fall within NEPM guidelines. In other words, an area may meet the NEPM requirements and yet still make residents sick.

Studies confirm that the relationship between particles in the air and childhood disease is "linear," which means that the more particles in the air, the more disease there is. This means that ANY increase in particles in the air is likely to cause disease in someone, somewhere. Any measure that decreases the amount (weight and numbers) of fine respirable particles should be promoted.

Respected leading experts - Professors Lidia Morawska and Michael Moore – writing in their

excellent review found at:

http://www.deh.gov.au/atmosphere/airquality/publications/health-impacts/index.html

state under 'Toxicology':

"All of the studies available to us demonstrate that the primary determinant of the effect

of ultrafine particles is their number and their surface area and not the weight of particles present

.This means that the traditional use of PM weight measures is inappropriate in evaluation of the

likely biological effects of ultrafine particles".

g) The CSIRO Protocol seems to assume that 350 million litres of biofuels (bio-diesel and bio-

ethanol) will be the limit (1-2%) in the total fuel market place and E5 and E10 will represent

the bulk of bio-ethanol fuel.

Note the same assumptions were made by the AIP as in the following link:

http://www.pmc.gov.au/biofuels/submissions/submission27.doc

Particulate Matter (PM) Particulate matter is a criteria air pollutant, and a PM10 standard is prescribed under the Ambient Air Quality NEPM. The PM10 standard is 50 µg/m3 (daily). There is no standard for PM2.5, though one is under consideration. There have been a number of studies in recent years of particulate matter from vehicle emissions under different vehicle and petrol standard scenarios throughout the world. The results differ considerably according to local vehicle technology. The effect of vehicle emissions on atmospheric concentrations of PM is also airshed specific. The estimates modelled by Coffey (2003) (the basis for decisions about the introduction of new vehicle standards and fuel standards in Australia), show very large reductions in PM emissions from vehicles. Emission control standards are in place for diesel vehicles as these have particulate emissions that are orders of magnitude greater than petrol vehicles. There are no emission standards anywhere in the world for PM emissions from petrol vehicles.

25 The figure below indicates the estimated reduction in PM emissions from the 2000 base case used by Coffey, including the impact of introducing Euro 3/4 fuel standards and vehicle ADRs in 2005/2006. Current fuels and vehicle standards are projected to result in a 50% reduction in particulate emissions from 2000 to 2010. Neither the introduction of future legislated conventional petrol and diesel standards (ie Euro 4/5 fuel standards and vehicle ADRs) in 2008/2009, or the addition of 350ML of ethanol to the 2020 fuel mix) is expected to have a significant impact on PM reduction in Australian urban areas.

PM emissions - current and legislated future fuel and vehicle standards

-2

0

2

4

6

8

10

12

14

2000 2005 2010 2015 2020

kt/y

ear

Total - current fuel and vehicle standards

Metro - current fuel and vehicle standards

Additonal reductions from move to Euro4/5petrol/dieselAdditional reductions from 350ML biofuels

Sources: Coffey (2003) - base, metro, Euro4/5 trends

ABARE, BTRE, CSIRO (2003) - E10 trends The key points for consideration are that:

• there are no particulate emissions standards for petrol engines anywhere in the world, only for diesel engines which are recognised as the major source of particulates.

• the Coffey Report (2003) concluded that peak 24 hour concentrations were generally well within the NEPM standard of 50 µg/m3 although this standard was exceeded in most Australian capital cities at least once a year mainly due to bushfires and dust storms. The NEPM goal allows five occurrences per year in excess of the standard and this goal was met by all Australian capital cities in 2001. A review of both PM standards and performance is expected this year.

• vehicle emissions of particulates are forecast to decline markedly with the mandated introduction of tighter vehicle ADRs and cleaner fuels

In summary, any impact of E10 on fine particulate emissions is not significant in the Australian context.

Comments: 1. The flaw in the above key points in the AIP statement is that PM10 is NOT a measure of tail-pipe

emissions. Studies by Morawska & Thomas (2000) concluded: “PM10 measurements provide information almost entirely on particles generated from mechanical processes. In an urban environment, this could mean particles resuspended by vehicular traffic and mechanical wear and tear, but not on the emission of motor vehicles.”

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While CSIRO/Orbital propose to measure coarse and fine particles, the analysis is not clear of how the relationship to health impact is to be determined.

2. Also noteworthy is that AIP as does CSIRO appear to IGNORE the claims of Dr Gary Whitten

that E10 reduces fine particles by a qualified 50%. See following link: http://www.ethanol-gec.org/information/briefing/13.pdf

h) CSIRO ‘smog’ analysis seems largely a repeat of their previous studies with E10.

The statements by AIP and conclusions regarding E10 and smog as extracted from the following link are relevant to the CSIRO Protocol:

http://www.pmc.gov.au/biofuels/submissions/submission27.doc

The potential effect of ethanol/ petrol blends on ozone formation depends on the impact of ethanol on VOC emissions and on any change in the reactivity of VOC emissions from ethanol compared to petrol. As outlined in the section on HC/VOCs, ethanol generally will reduce tailpipe emissions and increase evaporative emissions of VOCs. Modelling by CSIRO for the NSW (then) EPA in 2003 and by the Queensland EPA found that E10 blends would not increase or decrease ozone formation significantly. However, these studies did not consider a major increase in ethanol usage. Recent comprehensive US studies by the CRC and NRC (see section on HC/VOCs) found that ethanol blend fuels significantly increased emissions of VOCs, one of the two key smog precursors, which more than outweighed the relatively slight benefit from reducing aggregate CO emissions. This would indicate that any significant increase in the use of E10 blends would increase the potential for photochemical smog. In summary, ozone is a significant air quality issue in Australia. Ethanol blend fuels have both positive and negative effects on emissions of ozone precursors. Modelling in two States has shown that E10 blends would not increase or decrease ozone formation significantly. However, recent US studies have shown that E10 blends will increase the potential for smog occurrences.

Comment: Again, the benefits of E85, as a clean alternative fuel, have been excluded from the CSIRO Protocol. Why the bias?

i) CSIRO’s Protocol dealing with air toxics e.g., benzene, seems biased, without testing E85.

There is no safe level for benzene. The fact that only E5 and E10 but NOT E85 are being tested in the CSIRO Protocol carries a strong whiff of experimental subjectivity for presumed political expediency. Clearly, the failure to include E85 seems to be a form of open patronage of the Oil Companies as already the findings regarding benzene and E10 have been reported by the AIP at the following link:

http://www.pmc.gov.au/biofuels/submissions/submission27.doc

Noteworthy is the following extract:

In summary, current levels of ambient benzene concentrations are below the Air Toxic NEPM Investigation Level. Vehicle benzene emissions are set to decline further with the introduction of a maximum 1% benzene fuel standard in 2006. The introduction of an E10 blend petrol

27 using a base fuel complying with the benzene standards to apply in Australia from 1 January 2006, as part of the 350ML biofuels target would only lead to a marginal further reduction of benzene emission below that already achieved through the introduction of the new fuel and vehicle emission standards. In the absence of any Australian data to substantiate actual higher concentrations, or a scientifically established need for a lower ambient concentration limit, there is no case for mandatory use of E10 blend petrol to achieve benzene concentration targets for health reasons. The potential for formaldehyde and acetaldehyde emissions to increase as a result of use of E10 warrants further consideration.

j) In light of previous research into E5 and E10 undertaken by CSIRO et al., the outcomes of the proposed studies with E5 and E10 as an additive oxygenate are quite predictable. Will the failure of CSIRO to include E85 damage the benefits and marketing of E85 i.e., a clean renewable fuel? Reference is made to the AIP Submission to the Biofuels Taskforce. See link at:

http://www.pmc.gov.au/biofuels/submissions/submission27.doc

The generally negative case put by AIP against E10 leaves little doubt that predetermined confirmatory findings by CSIRO will add to the ‘alcohol damages engines’ media propaganda that has thwarted the introduction of alcohol as a fuel (E85) in Australia as opposed to progressive countries overseas. (See p 19 ‘Customer Demand for Biofuels’of AIP Submission). Will the CSIRO Protocol and its predetermined findings provide the evidence of another example of a research organization apparently aligning itself with the corporate polluter to augment profit and institutional financial benefits by passing the costs of health impacts to the community? The CSIRO Protocol would have immense credibility if it included E85 along with E5 and E10 in its comparative investigation. k) The CSIRO Protocol should include Premium Unleaded Petrol, in addition to E85. The Protocol aims to compare the health effects of ULP with E5 and E10 but FAILS to recognize that Premium Unleaded Petrol contains higher levels of aromatics, is more toxic, carcinogenic and evaporative. High-octane fuels (premium) require more energy to produce and they generate more toxic air emissions. More than 90% of cars do not need high octane fuel. I believe it would be responsible of CSIRO/Orbital to expose the octane fraud. As in the USA, the vast majority of cars require petrol with an octane rating of 87 or lower. For decades, oil companies have advertised and marketed to the public that the higher the octane rating, the better the car will operate and the cleaner the engine will become, and that these results will lead to reduced maintenance costs for the consumer. In fact, none of these representations is true for the overwhelming majority of cars. Octane demand is a situation forced on customers. CSIRO would do a service to disclose the fraud when all this pollution results in increased illness and premature deaths. The cost of octane fraud is fairly easy to quantify based on the volume of high-octane fuels sold compared with the number of vehicles that actually need it. l) The Protocol should be peer reviewed and the research by Orbital Australia must incorporate an independent auditor to validate the research Research that has the funding of an extraordinary large amount of tax-payers money should be subject to independent external peer review to validate e.g., appropriateness of statistical methods to eliminate bias and whether sampling is adequate to verify statistical significance. The CSIRO claim that the Protocol has been peer reviewed by “internal” experts is not adequate and has a whiff of a conflict of interest.

28 Equally, with such an important and expensive project with political and institutional imperatives at stake, not to mention the potential damage that flawed research can do to the ethanol alternative, I believe it is essential that the actual research by CSIRO and especially Orbital Australia MUST be audited (independently) for rigor and validity in the execution of this research. These precautions are intended to identify research bias and the inclusion of appropriate controls. m) The test fuels provided by the oil companies MUST be subject to independent verification. Since the fuels being tested will presumably come from the oil companies, it is imperative that there be a mechanism in place to ensure that the test fuels are audited/tested/verified independently and a third anonymous party is responsible for coding the samples so that the tests are ‘double’ blind and the testers are unaware of the category of test fuel. 15. Selection of References Atkinson R.W.1999‘Short-term associations between emergency hospital admissions for respiratory and cardiovascular disease and outdoor pollution in London.’ Arch.Resp. Cardio.Dis., 54:398-411.

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