Review of the Biofuels Act

Submission cover sheet

  • Name of organisation or individual making this submission

    Benjamin James Parker

  • Authorised delegate/contact person

    Benjamin James Parker

  • Position

    High Pressure Water Jetter

  • Organisation

    Sydney Trains

Questions on possible options

  1. Are the objects of the Biofuels Act and Regulation still valid? Why or why not?

    Yes absolutely. Because while Electric vehicles are advancing; there is still a large need for liquid fuels in Australia and there will be for some time. Because the energy density of liquid fuels cant be matched yet and Australia is so broad. So we must do what we can to minimise the impact of the unavoidable use of liquid fuels.

  2. Are there any other economic, social, environmental and consumer costs and benefits associated with biofuels that Government should further consider, to ensure that the regulatory regime is effective?

    I believe we should look at ways to cheapen biodiesel, to make it cheaper than petrodiesel. Maybe reduced tax depending on the concentration of biodiesel in b5, b20 and higher blends. Or maybe subsidies for biodiesel producers that rewards economical production. Seeing as high concentration biodiesel can be used in the vast majority of cars with no negative effects, the market would take to biodiesel rapidly if it was cheaper per litre for the end user. I will still always

  3. Are there any developments, innovations or emerging trends in the broader transport or fuel industry that Government should consider in assessing the biofuels regulatory regime?

    One thing that I’ve been following is the EPA’s push for E30 to be more widespread across America. Its a notion thats gaining traction. There has been much testing in the USA to see if standard cars with no alterations can handle E30. And apart from carburetter cars (which are obviously a rarity now) the trend has been no faults, cleaner emissions, surprisingly increased efficiency from the higher laminar flame speed, and increased safety from the cooling of the ethanol fraction. This increase from 4% ethanol concentration to 30% concentration across all sales would provide a massive benefit to the air quality, to our local farming industry, and to the motorists pocket seeing as the ethanol fraction is cheaper than petroleum, and as efficiency and engine cleanliness is up too. Another tech which appears promising but is admittedly very new is; butanol-producing Algae. Butanol can be a direct replacement for petroleum, and requires no modifications or recalibrations to run at 100% concentration. And it burns cleaner too. Im interested to see where this tech goes and i believe its worth a deeper look.

  4. Are there any entities that should be included in or excluded from the Act? If so, which entities and why?

    No, i am ok with who is included and excluded here.

  5. Are the definitions of volume fuel retailers and primary wholesalers adequate? If not, how could the definitions change?

    Yes they are adequate, but I’d like to see the numbers come down so more places were labelled as volume fuel retailers, to encourage more places to carry ethanol and biodiesel

  6. Does the Act appropriately balance the interests of small businesses with the broader objectives of the mandate? Please provide comments.

    No, it balances the interests of small business too favourably and to no benefit. Especially as ethanol blended fuels sell quite well. We can encourage the sale of ethanol harder safely without impacting anyone

  7. Should the prescribed mandate for ethanol and biodiesel sales remain at the current rate? If not, how should it change and why?

    It should go up sharply. Biofuels have proven benefits to our farmers, to motorists running costs, to the environment, and to the longevity of motorists powertrains. Id like to see the ethanol mandate increase to 11% and the biodiesel increase to 20% I picked 11% for ethanol; because this would encourage all fuel (91, 95, and 98) to be ethanol blended to come close to reaching targets, and it would encourage e85 bowsers and sales to make up the remaining 1% (a very achievable goal) in my proposed 11% target. This would help cause a growing network of e85 bowsers and would allow more people to run e85 cars for more of their travels. This would have a positive snowball effect: And i picked 20% biodiesel because there is no downside to higher concentrations like this. There is only benefits to this percentage and theres no reason for it to be as low as 2%. Its only cowardice to the petroleum industry thats kept this number so low.

  8. Are the biofuel sustainability standards adequate? Please provide comments.

    I see no issue here

  9. Are there emerging industry standards or developments that should be taken in to account when assessing and defining sustainability?

    I have no additional info here

  10. Is the exemption process for not meeting the minimum biofuels requirements adequate? Should the factors that the Minister must take in to account before granting an exemption change?

    The exemption process seems fair. I worry about corruption in the officers that grant exemptions. But thats not a discussion for this paper. The question is about the exemption process and i believe the criteria are fair

  11. What is the process like to seek an exemption? Are there any changes that could be made to ensure the process is as seamless and as user-friendly as possible?

    Seems fairly straightforward. Submit an application for an exemption stating your case. Its encouraged to do so beforehand instead of retrospectively. It seems pretty fair from my perspective.

  12. Is the Biofuels Exemption Framework and Guidelines document easy to understand and comply with? Should any of the matters outlined in the Guidelines be included instead in the Biofuels Regulation to ensure abundant legal clarity?

    Yes it appears clear and easy to comply with. It has leniency for extenuating circumstances and understanding. I see no need to change any of this. (Apart from my previously suggested increase of ethanol and biodiesel total sale fractions)

  13. Are the current registration, return and record keeping requirements adequate? Please provide comments.

    I cant really comment here. Im a motorist with an enthusiasm for biofuels. Im not a fuel seller. But seven years seems useful for trend data.

  14. How much time approximately does it take primary wholesales, volume fuel retailers and other operators of service stations to provide the return to NSW Fair Trading?

    Quartely

  15. What other reporting and financial regulatory requirements are primary wholesalers, volume fuel retailers and other operators of service stations required to comply with? For example, at the Commonwealth level.

    Fair Trading

  16. Are IPART’s functions and role adequate to help achieve the objectives of the Biofuels Act? Please provide comments.

    Yes

  17. Are there any other functions, research or role could IPART take in the biofuels regulatory regime?

    They could also encourage and monitor and suggest e85 pricing. And biodiesel blend pricing.

  18. What information and data would be useful in ensuring regulation fosters a competitive biofuels industry?

    ROI for biofuels manufacturers, including data on agriculture and theor current struggles (drought etc). This will help keep biofue pricing cheap but without breaking the manufacturers

  19. Is the current compliance and enforcement approach working well? Please provide comments.

    Seems to be a fair approach. Warnings and small fines before large enforcement actions happen. I do worry about volume fuel retailers submitting exemption applications constantly, and continually getting knocked back, but using the immunity from applying for an exemption to avoid fines.

  20. Is the current approach appropriate and should any changes be made (such as to penalty amounts) to make the compliance and enforcement approach more effective?

    No this seems fine

  21. Is the role and composition of the Biofuels Expert Panel still valid? Please provide comments.

    The role is fine. But i wish more scientific members were there, say from the CSIRO, instead of petroleum members.

  22. Do you have any other general comments on the biofuels regulatory regime? Please provide further detail.

    It should be encouraging ethanol to be used in all fuel. Not just some select pumps. If America can have e10-e15 available nationally, then why cant we?

At our discretion we may remove parts of submissions because of length, content, appropriateness or confidentiality (privacy) reasons.

Website https://www.fairtrading.nsw.gov.au

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