❓ A parliamentary question regarding a peer review of a report on fuel for Transperth buses, focusing on potential errors, increased costs, and health impacts. The Minister's response disputes the review's findings, citing updated data and flawed assumptions.
AnsweredQoN 70Legislative Council
QuestionView source ↗
(1) Is the minister aware that a team consisting of Dr Simon Taggart, Professor Lidia Morawska, Mr Bruce Higgs and Mr Bernard James has carried out a peer review of the expert reference group report “Euro 2 and Beyond: Fuel for Transperth’s Bus Fleet”? (2) Is the minister concerned that the review identified significant errors and omissions in the ERG report, and that the ERG recommendations will significantly increase Transperth’s operating costs, result in significant bus fleet fuel consumption overall, lead to increased greenhouse gas emissions, and increase the incidence of adverse toxic, asthmatic, genotoxic and carcinogenic health effects and human lung and respiratory diseases? (3) Does the minister intend to respond to the peer review findings; and if so, how? Hon M.J. CRIDDLE
AnswerView source ↗
I thank the member for some notice of this question. (1) Yes, I am aware of the review. Almost two years have elapsed between the release of the ERG report and the recent Euro 2 and beyond review. During that time the goods and services tax, the diesel and alternative fuels grants scheme, the alternative fuels conversion program and the compressed natural gas infrastructure program have been introduced. All these programs have a significant impact on the economic evaluation carried out at the time the ERG report was published. (2) Making comparisons between the two reports is now irrelevant as the Euro 2 and beyond review uses all post-GST figures, whereas the ERG report acknowledged the proposed introduction of the GST but used pre-GST figures. The Euro 2 and beyond review indicated that the introduction of Euro 2 engines and low sulfur fuels instead of natural gas, will increase the maintenance and operating cost of the Transperth bus fleet by $9 769 per bus per annum. This is not correct, as the report uses erroneous information with respect to the Transperth fleet, thereby painting a more positive outcome for natural gas than exists in reality. To arrive at this additional cost, the Euro 2 and beyond review made incorrect judgments and assumptions including the following - (a) The assumed bus delivery is understated in the early years and overstated in the later years. Actual deliveries from DaimlerChrysler are public knowledge and are greater in the early years of the program and reduce as the program progresses. (b) It wrongly assumed all buses delivered under the 848 bus replacement program will be Euro 2. DaimlerChrysler will phase out the Euro 2 engines and commence delivery of Euro 3 engines in January 2003 when Australian design rule 80 becomes available for existing models. (c) The review panel estimated that an increase in fuel consumption of up to 25 per cent would occur as a result of the use of low sulfur fuel and the addition of airconditioning. Fuel consumption returned by the new bus fleet is better than expected. The actual average fuel consumption of the new diesel bus fleet is 42.27 litres per 100 kilometres, operating on a fuel with a sulfur content of 0.05 per cent, or 500 parts per million. Operators report that the introduction of this fuel has not resulted in an increase in the fuel consumption of the remainder of the older fleet. (d) The review panel has factored in exhaust after-treatment maintenance costs for Euro 2 and Euro 3 engines when all European manufacturers supplying public transport buses state that Euro 2 and Euro 3 standards can be achieved without any exhaust after-treatment. (e) The current Transperth buses being supplied under the bus purchase and supply agreement are fitted with oxidising catalysts that do not require maintenance and last the life of the bus. The Euro 2 and beyond review made reference to ultra fine particles, and criticised the ERG report because it ignored the health effects of these smaller particles. A subsequent literature search on this issue has confirmed that the total mass of particulate matter is significantly reduced with the introduction of low sulfur fuels; however, the number of ultra fine particles is increased. Research in this area to date is incomplete, and there is no general agreement on the definition of fine particles and the techniques used to measure them. Reduction of the sulfur content in diesel fuel results in a reduction in the emission of sulphate particles. This is an established fact. A lot of research is still to be undertaken on the health effects of these ultra fine particles. European engine manufacturers are developing exhaust after-treatments, such as continuously regenerating particulate traps and oxidising catalysts, for use with low sulfur fuels that result in significant reductions in emission. Further research is needed to determine the effect of these exhaust after-treatments on the production of ultrafine particles. Because diesel is the dominant fuel used in Europe and throughout the world for buses, a great deal of research is being carried out by engine manufacturers to resolve the issues surrounding ultrafine particles. It is believed that the ERG and beyond review is not a balanced view as it was published by the Australasian Natural Gas Vehicles Council, which has a vested interest in the outcome. (3) The Government will continue to implement the recommendations of the ERG report so that informed decisions can be made with respect to the use of gas as a transport fuel. To this end, Transport has purchased five gas buses as part of the bus purchase and supply agreement. The chassis and engines for three of these buses have arrived in Australia and Transport is negotiating with Advanced Engine Components Ltd to fit its NGVS 4 multipoint fuel injection system to these engines. The other two normally aspirated natural gas buses will be delivered in early 2001. These modified gas engines will be tested in an independent facility to gauge compliance with the Euro 3 European transient cycle and their performance assessed against DaimlerChrysler’s low emission diesel as well as the two gas buses to be delivered in early 2001. Transport will use the information from these trials in the review to be conducted in 2003.
(2) Is the minister concerned that the review identified significant errors and omissions in the ERG report, and that the ERG recommendations will significantly increase Transperth’s operating costs, result in significant bus fleet fuel consumption overall, lead to increased greenhouse gas emissions, and increase the incidence of adverse toxic, asthmatic, genotoxic and carcinogenic health effects and human lung and respiratory diseases? (3) Does the minister intend to respond to the peer review findings; and if so, how? Hon M.J. CRIDDLE replied: I thank the member for some notice of this question. (1) Yes, I am aware of the review. Almost two years have elapsed between the release of the ERG report and the recent Euro 2 and beyond review. During that time the goods and services tax, the diesel and alternative fuels grants scheme, the alternative fuels conversion program and the compressed natural gas infrastructure program have been introduced. All these programs have a significant impact on the economic evaluation carried out at the time the ERG report was published. (2) Making comparisons between the two reports is now irrelevant as the Euro 2 and beyond review uses all post-GST figures, whereas the ERG report acknowledged the proposed introduction of the GST but used pre-GST figures. The Euro 2 and beyond review indicated that the introduction of Euro 2 engines and low sulfur fuels instead of natural gas, will increase the maintenance and operating cost of the Transperth bus fleet by $9 769 per bus per annum. This is not correct, as the report uses erroneous information with respect to the Transperth fleet, thereby painting a more positive outcome for natural gas than exists in reality. To arrive at this additional cost, the Euro 2 and beyond review made incorrect judgments and assumptions including the following - (a) The assumed bus delivery is understated in the early years and overstated in the later years. Actual deliveries from DaimlerChrysler are public knowledge and are greater in the early years of the program and reduce as the program progresses. (b) It wrongly assumed all buses delivered under the 848 bus replacement program will be Euro 2. DaimlerChrysler will phase out the Euro 2 engines and commence delivery of Euro 3 engines in January 2003 when Australian design rule 80 becomes available for existing models. (c) The review panel estimated that an increase in fuel consumption of up to 25 per cent would occur as a result of the use of low sulfur fuel and the addition of airconditioning. Fuel consumption returned by the new bus fleet is better than expected. The actual average fuel consumption of the new diesel bus fleet is 42.27 litres per 100 kilometres, operating on a fuel with a sulfur content of 0.05 per cent, or 500 parts per million. Operators report that the introduction of this fuel has not resulted in an increase in the fuel consumption of the remainder of the older fleet. (d) The review panel has factored in exhaust after-treatment maintenance costs for Euro 2 and Euro 3 engines when all European manufacturers supplying public transport buses state that Euro 2 and Euro 3 standards can be achieved without any exhaust after-treatment. (e) The current Transperth buses being supplied under the bus purchase and supply agreement are fitted with oxidising catalysts that do not require maintenance and last the life of the bus. The Euro 2 and beyond review made reference to ultra fine particles, and criticised the ERG report because it ignored the health effects of these smaller particles. A subsequent literature search on this issue has confirmed that the total mass of particulate matter is significantly reduced with the introduction of low sulfur fuels; however, the number of ultra fine particles is increased. Research in this area to date is incomplete, and there is no general agreement on the definition of fine particles and the techniques used to measure them. Reduction of the sulfur content in diesel fuel results in a reduction in the emission of sulphate particles. This is an established fact. A lot of research is still to be undertaken on the health effects of these ultra fine particles. European engine manufacturers are developing exhaust after-treatments, such as continuously regenerating particulate traps and oxidising catalysts, for use with low sulfur fuels that result in significant reductions in emission. Further research is needed to determine the effect of these exhaust after-treatments on the production of ultrafine particles. Because diesel is the dominant fuel used in Europe and throughout the world for buses, a great deal of research is being carried out by engine manufacturers to resolve the issues surrounding ultrafine particles. It is believed that the ERG and beyond review is not a balanced view as it was published by the Australasian Natural Gas Vehicles Council, which has a vested interest in the outcome. (3) The Government will continue to implement the recommendations of the ERG report so that informed decisions can be made with respect to the use of gas as a transport fuel. To this end, Transport has purchased five gas buses as part of the bus purchase and supply agreement. The chassis and engines for three of these buses have arrived in Australia and Transport is negotiating with Advanced Engine Components Ltd to fit its NGVS 4 multipoint fuel injection system to these engines. The other two normally aspirated natural gas buses will be delivered in early 2001. These modified gas engines will be tested in an independent facility to gauge compliance with the Euro 3 European transient cycle and their performance assessed against DaimlerChrysler’s low emission diesel as well as the two gas buses to be delivered in early 2001. Transport will use the information from these trials in the review to be conducted in 2003.
(3) Does the minister intend to respond to the peer review findings; and if so, how? Hon M.J. CRIDDLE replied: I thank the member for some notice of this question. (1) Yes, I am aware of the review. Almost two years have elapsed between the release of the ERG report and the recent Euro 2 and beyond review. During that time the goods and services tax, the diesel and alternative fuels grants scheme, the alternative fuels conversion program and the compressed natural gas infrastructure program have been introduced. All these programs have a significant impact on the economic evaluation carried out at the time the ERG report was published. (2) Making comparisons between the two reports is now irrelevant as the Euro 2 and beyond review uses all post-GST figures, whereas the ERG report acknowledged the proposed introduction of the GST but used pre-GST figures. The Euro 2 and beyond review indicated that the introduction of Euro 2 engines and low sulfur fuels instead of natural gas, will increase the maintenance and operating cost of the Transperth bus fleet by $9 769 per bus per annum. This is not correct, as the report uses erroneous information with respect to the Transperth fleet, thereby painting a more positive outcome for natural gas than exists in reality. To arrive at this additional cost, the Euro 2 and beyond review made incorrect judgments and assumptions including the following - (a) The assumed bus delivery is understated in the early years and overstated in the later years. Actual deliveries from DaimlerChrysler are public knowledge and are greater in the early years of the program and reduce as the program progresses. (b) It wrongly assumed all buses delivered under the 848 bus replacement program will be Euro 2. DaimlerChrysler will phase out the Euro 2 engines and commence delivery of Euro 3 engines in January 2003 when Australian design rule 80 becomes available for existing models. (c) The review panel estimated that an increase in fuel consumption of up to 25 per cent would occur as a result of the use of low sulfur fuel and the addition of airconditioning. Fuel consumption returned by the new bus fleet is better than expected. The actual average fuel consumption of the new diesel bus fleet is 42.27 litres per 100 kilometres, operating on a fuel with a sulfur content of 0.05 per cent, or 500 parts per million. Operators report that the introduction of this fuel has not resulted in an increase in the fuel consumption of the remainder of the older fleet. (d) The review panel has factored in exhaust after-treatment maintenance costs for Euro 2 and Euro 3 engines when all European manufacturers supplying public transport buses state that Euro 2 and Euro 3 standards can be achieved without any exhaust after-treatment. (e) The current Transperth buses being supplied under the bus purchase and supply agreement are fitted with oxidising catalysts that do not require maintenance and last the life of the bus. The Euro 2 and beyond review made reference to ultra fine particles, and criticised the ERG report because it ignored the health effects of these smaller particles. A subsequent literature search on this issue has confirmed that the total mass of particulate matter is significantly reduced with the introduction of low sulfur fuels; however, the number of ultra fine particles is increased. Research in this area to date is incomplete, and there is no general agreement on the definition of fine particles and the techniques used to measure them. Reduction of the sulfur content in diesel fuel results in a reduction in the emission of sulphate particles. This is an established fact. A lot of research is still to be undertaken on the health effects of these ultra fine particles. European engine manufacturers are developing exhaust after-treatments, such as continuously regenerating particulate traps and oxidising catalysts, for use with low sulfur fuels that result in significant reductions in emission. Further research is needed to determine the effect of these exhaust after-treatments on the production of ultrafine particles. Because diesel is the dominant fuel used in Europe and throughout the world for buses, a great deal of research is being carried out by engine manufacturers to resolve the issues surrounding ultrafine particles. It is believed that the ERG and beyond review is not a balanced view as it was published by the Australasian Natural Gas Vehicles Council, which has a vested interest in the outcome. (3) The Government will continue to implement the recommendations of the ERG report so that informed decisions can be made with respect to the use of gas as a transport fuel. To this end, Transport has purchased five gas buses as part of the bus purchase and supply agreement. The chassis and engines for three of these buses have arrived in Australia and Transport is negotiating with Advanced Engine Components Ltd to fit its NGVS 4 multipoint fuel injection system to these engines. The other two normally aspirated natural gas buses will be delivered in early 2001. These modified gas engines will be tested in an independent facility to gauge compliance with the Euro 3 European transient cycle and their performance assessed against DaimlerChrysler’s low emission diesel as well as the two gas buses to be delivered in early 2001. Transport will use the information from these trials in the review to be conducted in 2003.
Hon M.J. CRIDDLE replied: I thank the member for some notice of this question. (1) Yes, I am aware of the review. Almost two years have elapsed between the release of the ERG report and the recent Euro 2 and beyond review. During that time the goods and services tax, the diesel and alternative fuels grants scheme, the alternative fuels conversion program and the compressed natural gas infrastructure program have been introduced. All these programs have a significant impact on the economic evaluation carried out at the time the ERG report was published. (2) Making comparisons between the two reports is now irrelevant as the Euro 2 and beyond review uses all post-GST figures, whereas the ERG report acknowledged the proposed introduction of the GST but used pre-GST figures. The Euro 2 and beyond review indicated that the introduction of Euro 2 engines and low sulfur fuels instead of natural gas, will increase the maintenance and operating cost of the Transperth bus fleet by $9 769 per bus per annum. This is not correct, as the report uses erroneous information with respect to the Transperth fleet, thereby painting a more positive outcome for natural gas than exists in reality. To arrive at this additional cost, the Euro 2 and beyond review made incorrect judgments and assumptions including the following - (a) The assumed bus delivery is understated in the early years and overstated in the later years. Actual deliveries from DaimlerChrysler are public knowledge and are greater in the early years of the program and reduce as the program progresses. (b) It wrongly assumed all buses delivered under the 848 bus replacement program will be Euro 2. DaimlerChrysler will phase out the Euro 2 engines and commence delivery of Euro 3 engines in January 2003 when Australian design rule 80 becomes available for existing models. (c) The review panel estimated that an increase in fuel consumption of up to 25 per cent would occur as a result of the use of low sulfur fuel and the addition of airconditioning. Fuel consumption returned by the new bus fleet is better than expected. The actual average fuel consumption of the new diesel bus fleet is 42.27 litres per 100 kilometres, operating on a fuel with a sulfur content of 0.05 per cent, or 500 parts per million. Operators report that the introduction of this fuel has not resulted in an increase in the fuel consumption of the remainder of the older fleet. (d) The review panel has factored in exhaust after-treatment maintenance costs for Euro 2 and Euro 3 engines when all European manufacturers supplying public transport buses state that Euro 2 and Euro 3 standards can be achieved without any exhaust after-treatment. (e) The current Transperth buses being supplied under the bus purchase and supply agreement are fitted with oxidising catalysts that do not require maintenance and last the life of the bus. The Euro 2 and beyond review made reference to ultra fine particles, and criticised the ERG report because it ignored the health effects of these smaller particles. A subsequent literature search on this issue has confirmed that the total mass of particulate matter is significantly reduced with the introduction of low sulfur fuels; however, the number of ultra fine particles is increased. Research in this area to date is incomplete, and there is no general agreement on the definition of fine particles and the techniques used to measure them. Reduction of the sulfur content in diesel fuel results in a reduction in the emission of sulphate particles. This is an established fact. A lot of research is still to be undertaken on the health effects of these ultra fine particles. European engine manufacturers are developing exhaust after-treatments, such as continuously regenerating particulate traps and oxidising catalysts, for use with low sulfur fuels that result in significant reductions in emission. Further research is needed to determine the effect of these exhaust after-treatments on the production of ultrafine particles. Because diesel is the dominant fuel used in Europe and throughout the world for buses, a great deal of research is being carried out by engine manufacturers to resolve the issues surrounding ultrafine particles. It is believed that the ERG and beyond review is not a balanced view as it was published by the Australasian Natural Gas Vehicles Council, which has a vested interest in the outcome. (3) The Government will continue to implement the recommendations of the ERG report so that informed decisions can be made with respect to the use of gas as a transport fuel. To this end, Transport has purchased five gas buses as part of the bus purchase and supply agreement. The chassis and engines for three of these buses have arrived in Australia and Transport is negotiating with Advanced Engine Components Ltd to fit its NGVS 4 multipoint fuel injection system to these engines. The other two normally aspirated natural gas buses will be delivered in early 2001. These modified gas engines will be tested in an independent facility to gauge compliance with the Euro 3 European transient cycle and their performance assessed against DaimlerChrysler’s low emission diesel as well as the two gas buses to be delivered in early 2001. Transport will use the information from these trials in the review to be conducted in 2003.
I thank the member for some notice of this question. (1) Yes, I am aware of the review. Almost two years have elapsed between the release of the ERG report and the recent Euro 2 and beyond review. During that time the goods and services tax, the diesel and alternative fuels grants scheme, the alternative fuels conversion program and the compressed natural gas infrastructure program have been introduced. All these programs have a significant impact on the economic evaluation carried out at the time the ERG report was published. (2) Making comparisons between the two reports is now irrelevant as the Euro 2 and beyond review uses all post-GST figures, whereas the ERG report acknowledged the proposed introduction of the GST but used pre-GST figures. The Euro 2 and beyond review indicated that the introduction of Euro 2 engines and low sulfur fuels instead of natural gas, will increase the maintenance and operating cost of the Transperth bus fleet by $9 769 per bus per annum. This is not correct, as the report uses erroneous information with respect to the Transperth fleet, thereby painting a more positive outcome for natural gas than exists in reality. To arrive at this additional cost, the Euro 2 and beyond review made incorrect judgments and assumptions including the following - (a) The assumed bus delivery is understated in the early years and overstated in the later years. Actual deliveries from DaimlerChrysler are public knowledge and are greater in the early years of the program and reduce as the program progresses. (b) It wrongly assumed all buses delivered under the 848 bus replacement program will be Euro 2. DaimlerChrysler will phase out the Euro 2 engines and commence delivery of Euro 3 engines in January 2003 when Australian design rule 80 becomes available for existing models. (c) The review panel estimated that an increase in fuel consumption of up to 25 per cent would occur as a result of the use of low sulfur fuel and the addition of airconditioning. Fuel consumption returned by the new bus fleet is better than expected. The actual average fuel consumption of the new diesel bus fleet is 42.27 litres per 100 kilometres, operating on a fuel with a sulfur content of 0.05 per cent, or 500 parts per million. Operators report that the introduction of this fuel has not resulted in an increase in the fuel consumption of the remainder of the older fleet. (d) The review panel has factored in exhaust after-treatment maintenance costs for Euro 2 and Euro 3 engines when all European manufacturers supplying public transport buses state that Euro 2 and Euro 3 standards can be achieved without any exhaust after-treatment. (e) The current Transperth buses being supplied under the bus purchase and supply agreement are fitted with oxidising catalysts that do not require maintenance and last the life of the bus. The Euro 2 and beyond review made reference to ultra fine particles, and criticised the ERG report because it ignored the health effects of these smaller particles. A subsequent literature search on this issue has confirmed that the total mass of particulate matter is significantly reduced with the introduction of low sulfur fuels; however, the number of ultra fine particles is increased. Research in this area to date is incomplete, and there is no general agreement on the definition of fine particles and the techniques used to measure them. Reduction of the sulfur content in diesel fuel results in a reduction in the emission of sulphate particles. This is an established fact. A lot of research is still to be undertaken on the health effects of these ultra fine particles. European engine manufacturers are developing exhaust after-treatments, such as continuously regenerating particulate traps and oxidising catalysts, for use with low sulfur fuels that result in significant reductions in emission. Further research is needed to determine the effect of these exhaust after-treatments on the production of ultrafine particles. Because diesel is the dominant fuel used in Europe and throughout the world for buses, a great deal of research is being carried out by engine manufacturers to resolve the issues surrounding ultrafine particles. It is believed that the ERG and beyond review is not a balanced view as it was published by the Australasian Natural Gas Vehicles Council, which has a vested interest in the outcome. (3) The Government will continue to implement the recommendations of the ERG report so that informed decisions can be made with respect to the use of gas as a transport fuel. To this end, Transport has purchased five gas buses as part of the bus purchase and supply agreement. The chassis and engines for three of these buses have arrived in Australia and Transport is negotiating with Advanced Engine Components Ltd to fit its NGVS 4 multipoint fuel injection system to these engines. The other two normally aspirated natural gas buses will be delivered in early 2001. These modified gas engines will be tested in an independent facility to gauge compliance with the Euro 3 European transient cycle and their performance assessed against DaimlerChrysler’s low emission diesel as well as the two gas buses to be delivered in early 2001. Transport will use the information from these trials in the review to be conducted in 2003.
(1) Yes, I am aware of the review. Almost two years have elapsed between the release of the ERG report and the recent Euro 2 and beyond review. During that time the goods and services tax, the diesel and alternative fuels grants scheme, the alternative fuels conversion program and the compressed natural gas infrastructure program have been introduced. All these programs have a significant impact on the economic evaluation carried out at the time the ERG report was published. (2) Making comparisons between the two reports is now irrelevant as the Euro 2 and beyond review uses all post-GST figures, whereas the ERG report acknowledged the proposed introduction of the GST but used pre-GST figures. The Euro 2 and beyond review indicated that the introduction of Euro 2 engines and low sulfur fuels instead of natural gas, will increase the maintenance and operating cost of the Transperth bus fleet by $9 769 per bus per annum. This is not correct, as the report uses erroneous information with respect to the Transperth fleet, thereby painting a more positive outcome for natural gas than exists in reality. To arrive at this additional cost, the Euro 2 and beyond review made incorrect judgments and assumptions including the following - (a) The assumed bus delivery is understated in the early years and overstated in the later years. Actual deliveries from DaimlerChrysler are public knowledge and are greater in the early years of the program and reduce as the program progresses. (b) It wrongly assumed all buses delivered under the 848 bus replacement program will be Euro 2. DaimlerChrysler will phase out the Euro 2 engines and commence delivery of Euro 3 engines in January 2003 when Australian design rule 80 becomes available for existing models. (c) The review panel estimated that an increase in fuel consumption of up to 25 per cent would occur as a result of the use of low sulfur fuel and the addition of airconditioning. Fuel consumption returned by the new bus fleet is better than expected. The actual average fuel consumption of the new diesel bus fleet is 42.27 litres per 100 kilometres, operating on a fuel with a sulfur content of 0.05 per cent, or 500 parts per million. Operators report that the introduction of this fuel has not resulted in an increase in the fuel consumption of the remainder of the older fleet. (d) The review panel has factored in exhaust after-treatment maintenance costs for Euro 2 and Euro 3 engines when all European manufacturers supplying public transport buses state that Euro 2 and Euro 3 standards can be achieved without any exhaust after-treatment. (e) The current Transperth buses being supplied under the bus purchase and supply agreement are fitted with oxidising catalysts that do not require maintenance and last the life of the bus. The Euro 2 and beyond review made reference to ultra fine particles, and criticised the ERG report because it ignored the health effects of these smaller particles. A subsequent literature search on this issue has confirmed that the total mass of particulate matter is significantly reduced with the introduction of low sulfur fuels; however, the number of ultra fine particles is increased. Research in this area to date is incomplete, and there is no general agreement on the definition of fine particles and the techniques used to measure them. Reduction of the sulfur content in diesel fuel results in a reduction in the emission of sulphate particles. This is an established fact. A lot of research is still to be undertaken on the health effects of these ultra fine particles. European engine manufacturers are developing exhaust after-treatments, such as continuously regenerating particulate traps and oxidising catalysts, for use with low sulfur fuels that result in significant reductions in emission. Further research is needed to determine the effect of these exhaust after-treatments on the production of ultrafine particles. Because diesel is the dominant fuel used in Europe and throughout the world for buses, a great deal of research is being carried out by engine manufacturers to resolve the issues surrounding ultrafine particles. It is believed that the ERG and beyond review is not a balanced view as it was published by the Australasian Natural Gas Vehicles Council, which has a vested interest in the outcome. (3) The Government will continue to implement the recommendations of the ERG report so that informed decisions can be made with respect to the use of gas as a transport fuel. To this end, Transport has purchased five gas buses as part of the bus purchase and supply agreement. The chassis and engines for three of these buses have arrived in Australia and Transport is negotiating with Advanced Engine Components Ltd to fit its NGVS 4 multipoint fuel injection system to these engines. The other two normally aspirated natural gas buses will be delivered in early 2001. These modified gas engines will be tested in an independent facility to gauge compliance with the Euro 3 European transient cycle and their performance assessed against DaimlerChrysler’s low emission diesel as well as the two gas buses to be delivered in early 2001. Transport will use the information from these trials in the review to be conducted in 2003.
(2) Making comparisons between the two reports is now irrelevant as the Euro 2 and beyond review uses all post-GST figures, whereas the ERG report acknowledged the proposed introduction of the GST but used pre-GST figures. The Euro 2 and beyond review indicated that the introduction of Euro 2 engines and low sulfur fuels instead of natural gas, will increase the maintenance and operating cost of the Transperth bus fleet by $9 769 per bus per annum. This is not correct, as the report uses erroneous information with respect to the Transperth fleet, thereby painting a more positive outcome for natural gas than exists in reality. To arrive at this additional cost, the Euro 2 and beyond review made incorrect judgments and assumptions including the following - (a) The assumed bus delivery is understated in the early years and overstated in the later years. Actual deliveries from DaimlerChrysler are public knowledge and are greater in the early years of the program and reduce as the program progresses. (b) It wrongly assumed all buses delivered under the 848 bus replacement program will be Euro 2. DaimlerChrysler will phase out the Euro 2 engines and commence delivery of Euro 3 engines in January 2003 when Australian design rule 80 becomes available for existing models. (c) The review panel estimated that an increase in fuel consumption of up to 25 per cent would occur as a result of the use of low sulfur fuel and the addition of airconditioning. Fuel consumption returned by the new bus fleet is better than expected. The actual average fuel consumption of the new diesel bus fleet is 42.27 litres per 100 kilometres, operating on a fuel with a sulfur content of 0.05 per cent, or 500 parts per million. Operators report that the introduction of this fuel has not resulted in an increase in the fuel consumption of the remainder of the older fleet. (d) The review panel has factored in exhaust after-treatment maintenance costs for Euro 2 and Euro 3 engines when all European manufacturers supplying public transport buses state that Euro 2 and Euro 3 standards can be achieved without any exhaust after-treatment. (e) The current Transperth buses being supplied under the bus purchase and supply agreement are fitted with oxidising catalysts that do not require maintenance and last the life of the bus. The Euro 2 and beyond review made reference to ultra fine particles, and criticised the ERG report because it ignored the health effects of these smaller particles. A subsequent literature search on this issue has confirmed that the total mass of particulate matter is significantly reduced with the introduction of low sulfur fuels; however, the number of ultra fine particles is increased. Research in this area to date is incomplete, and there is no general agreement on the definition of fine particles and the techniques used to measure them. Reduction of the sulfur content in diesel fuel results in a reduction in the emission of sulphate particles. This is an established fact. A lot of research is still to be undertaken on the health effects of these ultra fine particles. European engine manufacturers are developing exhaust after-treatments, such as continuously regenerating particulate traps and oxidising catalysts, for use with low sulfur fuels that result in significant reductions in emission. Further research is needed to determine the effect of these exhaust after-treatments on the production of ultrafine particles. Because diesel is the dominant fuel used in Europe and throughout the world for buses, a great deal of research is being carried out by engine manufacturers to resolve the issues surrounding ultrafine particles. It is believed that the ERG and beyond review is not a balanced view as it was published by the Australasian Natural Gas Vehicles Council, which has a vested interest in the outcome. (3) The Government will continue to implement the recommendations of the ERG report so that informed decisions can be made with respect to the use of gas as a transport fuel. To this end, Transport has purchased five gas buses as part of the bus purchase and supply agreement. The chassis and engines for three of these buses have arrived in Australia and Transport is negotiating with Advanced Engine Components Ltd to fit its NGVS 4 multipoint fuel injection system to these engines. The other two normally aspirated natural gas buses will be delivered in early 2001. These modified gas engines will be tested in an independent facility to gauge compliance with the Euro 3 European transient cycle and their performance assessed against DaimlerChrysler’s low emission diesel as well as the two gas buses to be delivered in early 2001. Transport will use the information from these trials in the review to be conducted in 2003.
(a) The assumed bus delivery is understated in the early years and overstated in the later years. Actual deliveries from DaimlerChrysler are public knowledge and are greater in the early years of the program and reduce as the program progresses. (b) It wrongly assumed all buses delivered under the 848 bus replacement program will be Euro 2. DaimlerChrysler will phase out the Euro 2 engines and commence delivery of Euro 3 engines in January 2003 when Australian design rule 80 becomes available for existing models. (c) The review panel estimated that an increase in fuel consumption of up to 25 per cent would occur as a result of the use of low sulfur fuel and the addition of airconditioning. Fuel consumption returned by the new bus fleet is better than expected. The actual average fuel consumption of the new diesel bus fleet is 42.27 litres per 100 kilometres, operating on a fuel with a sulfur content of 0.05 per cent, or 500 parts per million. Operators report that the introduction of this fuel has not resulted in an increase in the fuel consumption of the remainder of the older fleet. (d) The review panel has factored in exhaust after-treatment maintenance costs for Euro 2 and Euro 3 engines when all European manufacturers supplying public transport buses state that Euro 2 and Euro 3 standards can be achieved without any exhaust after-treatment. (e) The current Transperth buses being supplied under the bus purchase and supply agreement are fitted with oxidising catalysts that do not require maintenance and last the life of the bus. The Euro 2 and beyond review made reference to ultra fine particles, and criticised the ERG report because it ignored the health effects of these smaller particles. A subsequent literature search on this issue has confirmed that the total mass of particulate matter is significantly reduced with the introduction of low sulfur fuels; however, the number of ultra fine particles is increased. Research in this area to date is incomplete, and there is no general agreement on the definition of fine particles and the techniques used to measure them. Reduction of the sulfur content in diesel fuel results in a reduction in the emission of sulphate particles. This is an established fact. A lot of research is still to be undertaken on the health effects of these ultra fine particles. European engine manufacturers are developing exhaust after-treatments, such as continuously regenerating particulate traps and oxidising catalysts, for use with low sulfur fuels that result in significant reductions in emission.
(b) It wrongly assumed all buses delivered under the 848 bus replacement program will be Euro 2. DaimlerChrysler will phase out the Euro 2 engines and commence delivery of Euro 3 engines in January 2003 when Australian design rule 80 becomes available for existing models. (c) The review panel estimated that an increase in fuel consumption of up to 25 per cent would occur as a result of the use of low sulfur fuel and the addition of airconditioning. Fuel consumption returned by the new bus fleet is better than expected. The actual average fuel consumption of the new diesel bus fleet is 42.27 litres per 100 kilometres, operating on a fuel with a sulfur content of 0.05 per cent, or 500 parts per million. Operators report that the introduction of this fuel has not resulted in an increase in the fuel consumption of the remainder of the older fleet. (d) The review panel has factored in exhaust after-treatment maintenance costs for Euro 2 and Euro 3 engines when all European manufacturers supplying public transport buses state that Euro 2 and Euro 3 standards can be achieved without any exhaust after-treatment. (e) The current Transperth buses being supplied under the bus purchase and supply agreement are fitted with oxidising catalysts that do not require maintenance and last the life of the bus. The Euro 2 and beyond review made reference to ultra fine particles, and criticised the ERG report because it ignored the health effects of these smaller particles. A subsequent literature search on this issue has confirmed that the total mass of particulate matter is significantly reduced with the introduction of low sulfur fuels; however, the number of ultra fine particles is increased. Research in this area to date is incomplete, and there is no general agreement on the definition of fine particles and the techniques used to measure them. Reduction of the sulfur content in diesel fuel results in a reduction in the emission of sulphate particles. This is an established fact. A lot of research is still to be undertaken on the health effects of these ultra fine particles. European engine manufacturers are developing exhaust after-treatments, such as continuously regenerating particulate traps and oxidising catalysts, for use with low sulfur fuels that result in significant reductions in emission.
(c) The review panel estimated that an increase in fuel consumption of up to 25 per cent would occur as a result of the use of low sulfur fuel and the addition of airconditioning. Fuel consumption returned by the new bus fleet is better than expected. The actual average fuel consumption of the new diesel bus fleet is 42.27 litres per 100 kilometres, operating on a fuel with a sulfur content of 0.05 per cent, or 500 parts per million. Operators report that the introduction of this fuel has not resulted in an increase in the fuel consumption of the remainder of the older fleet. (d) The review panel has factored in exhaust after-treatment maintenance costs for Euro 2 and Euro 3 engines when all European manufacturers supplying public transport buses state that Euro 2 and Euro 3 standards can be achieved without any exhaust after-treatment. (e) The current Transperth buses being supplied under the bus purchase and supply agreement are fitted with oxidising catalysts that do not require maintenance and last the life of the bus. The Euro 2 and beyond review made reference to ultra fine particles, and criticised the ERG report because it ignored the health effects of these smaller particles. A subsequent literature search on this issue has confirmed that the total mass of particulate matter is significantly reduced with the introduction of low sulfur fuels; however, the number of ultra fine particles is increased. Research in this area to date is incomplete, and there is no general agreement on the definition of fine particles and the techniques used to measure them. Reduction of the sulfur content in diesel fuel results in a reduction in the emission of sulphate particles. This is an established fact. A lot of research is still to be undertaken on the health effects of these ultra fine particles. European engine manufacturers are developing exhaust after-treatments, such as continuously regenerating particulate traps and oxidising catalysts, for use with low sulfur fuels that result in significant reductions in emission.
(d) The review panel has factored in exhaust after-treatment maintenance costs for Euro 2 and Euro 3 engines when all European manufacturers supplying public transport buses state that Euro 2 and Euro 3 standards can be achieved without any exhaust after-treatment. (e) The current Transperth buses being supplied under the bus purchase and supply agreement are fitted with oxidising catalysts that do not require maintenance and last the life of the bus. The Euro 2 and beyond review made reference to ultra fine particles, and criticised the ERG report because it ignored the health effects of these smaller particles. A subsequent literature search on this issue has confirmed that the total mass of particulate matter is significantly reduced with the introduction of low sulfur fuels; however, the number of ultra fine particles is increased. Research in this area to date is incomplete, and there is no general agreement on the definition of fine particles and the techniques used to measure them. Reduction of the sulfur content in diesel fuel results in a reduction in the emission of sulphate particles. This is an established fact. A lot of research is still to be undertaken on the health effects of these ultra fine particles. European engine manufacturers are developing exhaust after-treatments, such as continuously regenerating particulate traps and oxidising catalysts, for use with low sulfur fuels that result in significant reductions in emission.
(e) The current Transperth buses being supplied under the bus purchase and supply agreement are fitted with oxidising catalysts that do not require maintenance and last the life of the bus. The Euro 2 and beyond review made reference to ultra fine particles, and criticised the ERG report because it ignored the health effects of these smaller particles. A subsequent literature search on this issue has confirmed that the total mass of particulate matter is significantly reduced with the introduction of low sulfur fuels; however, the number of ultra fine particles is increased. Research in this area to date is incomplete, and there is no general agreement on the definition of fine particles and the techniques used to measure them. Reduction of the sulfur content in diesel fuel results in a reduction in the emission of sulphate particles. This is an established fact. A lot of research is still to be undertaken on the health effects of these ultra fine particles. European engine manufacturers are developing exhaust after-treatments, such as continuously regenerating particulate traps and oxidising catalysts, for use with low sulfur fuels that result in significant reductions in emission.
The Euro 2 and beyond review made reference to ultra fine particles, and criticised the ERG report because it ignored the health effects of these smaller particles. A subsequent literature search on this issue has confirmed that the total mass of particulate matter is significantly reduced with the introduction of low sulfur fuels; however, the number of ultra fine particles is increased. Research in this area to date is incomplete, and there is no general agreement on the definition of fine particles and the techniques used to measure them. Reduction of the sulfur content in diesel fuel results in a reduction in the emission of sulphate particles. This is an established fact. A lot of research is still to be undertaken on the health effects of these ultra fine particles. European engine manufacturers are developing exhaust after-treatments, such as continuously regenerating particulate traps and oxidising catalysts, for use with low sulfur fuels that result in significant reductions in emission.
European engine manufacturers are developing exhaust after-treatments, such as continuously regenerating particulate traps and oxidising catalysts, for use with low sulfur fuels that result in significant reductions in emission.
It is believed that the ERG and beyond review is not a balanced view as it was published by the Australasian Natural Gas Vehicles Council, which has a vested interest in the outcome. (3) The Government will continue to implement the recommendations of the ERG report so that informed decisions can be made with respect to the use of gas as a transport fuel. To this end, Transport has purchased five gas buses as part of the bus purchase and supply agreement. The chassis and engines for three of these buses have arrived in Australia and Transport is negotiating with Advanced Engine Components Ltd to fit its NGVS 4 multipoint fuel injection system to these engines. The other two normally aspirated natural gas buses will be delivered in early 2001. These modified gas engines will be tested in an independent facility to gauge compliance with the Euro 3 European transient cycle and their performance assessed against DaimlerChrysler’s low emission diesel as well as the two gas buses to be delivered in early 2001. Transport will use the information from these trials in the review to be conducted in 2003.
(3) The Government will continue to implement the recommendations of the ERG report so that informed decisions can be made with respect to the use of gas as a transport fuel. To this end, Transport has purchased five gas buses as part of the bus purchase and supply agreement. The chassis and engines for three of these buses have arrived in Australia and Transport is negotiating with Advanced Engine Components Ltd to fit its NGVS 4 multipoint fuel injection system to these engines. The other two normally aspirated natural gas buses will be delivered in early 2001. These modified gas engines will be tested in an independent facility to gauge compliance with the Euro 3 European transient cycle and their performance assessed against DaimlerChrysler’s low emission diesel as well as the two gas buses to be delivered in early 2001. Transport will use the information from these trials in the review to be conducted in 2003.
These modified gas engines will be tested in an independent facility to gauge compliance with the Euro 3 European transient cycle and their performance assessed against DaimlerChrysler’s low emission diesel as well as the two gas buses to be delivered in early 2001. Transport will use the information from these trials in the review to be conducted in 2003.
(2) Is the minister concerned that the review identified significant errors and omissions in the ERG report, and that the ERG recommendations will significantly increase Transperth’s operating costs, result in significant bus fleet fuel consumption overall, lead to increased greenhouse gas emissions, and increase the incidence of adverse toxic, asthmatic, genotoxic and carcinogenic health effects and human lung and respiratory diseases? (3) Does the minister intend to respond to the peer review findings; and if so, how? Hon M.J. CRIDDLE replied: I thank the member for some notice of this question. (1) Yes, I am aware of the review. Almost two years have elapsed between the release of the ERG report and the recent Euro 2 and beyond review. During that time the goods and services tax, the diesel and alternative fuels grants scheme, the alternative fuels conversion program and the compressed natural gas infrastructure program have been introduced. All these programs have a significant impact on the economic evaluation carried out at the time the ERG report was published. (2) Making comparisons between the two reports is now irrelevant as the Euro 2 and beyond review uses all post-GST figures, whereas the ERG report acknowledged the proposed introduction of the GST but used pre-GST figures. The Euro 2 and beyond review indicated that the introduction of Euro 2 engines and low sulfur fuels instead of natural gas, will increase the maintenance and operating cost of the Transperth bus fleet by $9 769 per bus per annum. This is not correct, as the report uses erroneous information with respect to the Transperth fleet, thereby painting a more positive outcome for natural gas than exists in reality. To arrive at this additional cost, the Euro 2 and beyond review made incorrect judgments and assumptions including the following - (a) The assumed bus delivery is understated in the early years and overstated in the later years. Actual deliveries from DaimlerChrysler are public knowledge and are greater in the early years of the program and reduce as the program progresses. (b) It wrongly assumed all buses delivered under the 848 bus replacement program will be Euro 2. DaimlerChrysler will phase out the Euro 2 engines and commence delivery of Euro 3 engines in January 2003 when Australian design rule 80 becomes available for existing models. (c) The review panel estimated that an increase in fuel consumption of up to 25 per cent would occur as a result of the use of low sulfur fuel and the addition of airconditioning. Fuel consumption returned by the new bus fleet is better than expected. The actual average fuel consumption of the new diesel bus fleet is 42.27 litres per 100 kilometres, operating on a fuel with a sulfur content of 0.05 per cent, or 500 parts per million. Operators report that the introduction of this fuel has not resulted in an increase in the fuel consumption of the remainder of the older fleet. (d) The review panel has factored in exhaust after-treatment maintenance costs for Euro 2 and Euro 3 engines when all European manufacturers supplying public transport buses state that Euro 2 and Euro 3 standards can be achieved without any exhaust after-treatment. (e) The current Transperth buses being supplied under the bus purchase and supply agreement are fitted with oxidising catalysts that do not require maintenance and last the life of the bus. The Euro 2 and beyond review made reference to ultra fine particles, and criticised the ERG report because it ignored the health effects of these smaller particles. A subsequent literature search on this issue has confirmed that the total mass of particulate matter is significantly reduced with the introduction of low sulfur fuels; however, the number of ultra fine particles is increased. Research in this area to date is incomplete, and there is no general agreement on the definition of fine particles and the techniques used to measure them. Reduction of the sulfur content in diesel fuel results in a reduction in the emission of sulphate particles. This is an established fact. A lot of research is still to be undertaken on the health effects of these ultra fine particles. European engine manufacturers are developing exhaust after-treatments, such as continuously regenerating particulate traps and oxidising catalysts, for use with low sulfur fuels that result in significant reductions in emission. Further research is needed to determine the effect of these exhaust after-treatments on the production of ultrafine particles. Because diesel is the dominant fuel used in Europe and throughout the world for buses, a great deal of research is being carried out by engine manufacturers to resolve the issues surrounding ultrafine particles. It is believed that the ERG and beyond review is not a balanced view as it was published by the Australasian Natural Gas Vehicles Council, which has a vested interest in the outcome. (3) The Government will continue to implement the recommendations of the ERG report so that informed decisions can be made with respect to the use of gas as a transport fuel. To this end, Transport has purchased five gas buses as part of the bus purchase and supply agreement. The chassis and engines for three of these buses have arrived in Australia and Transport is negotiating with Advanced Engine Components Ltd to fit its NGVS 4 multipoint fuel injection system to these engines. The other two normally aspirated natural gas buses will be delivered in early 2001. These modified gas engines will be tested in an independent facility to gauge compliance with the Euro 3 European transient cycle and their performance assessed against DaimlerChrysler’s low emission diesel as well as the two gas buses to be delivered in early 2001. Transport will use the information from these trials in the review to be conducted in 2003.
(3) Does the minister intend to respond to the peer review findings; and if so, how? Hon M.J. CRIDDLE replied: I thank the member for some notice of this question. (1) Yes, I am aware of the review. Almost two years have elapsed between the release of the ERG report and the recent Euro 2 and beyond review. During that time the goods and services tax, the diesel and alternative fuels grants scheme, the alternative fuels conversion program and the compressed natural gas infrastructure program have been introduced. All these programs have a significant impact on the economic evaluation carried out at the time the ERG report was published. (2) Making comparisons between the two reports is now irrelevant as the Euro 2 and beyond review uses all post-GST figures, whereas the ERG report acknowledged the proposed introduction of the GST but used pre-GST figures. The Euro 2 and beyond review indicated that the introduction of Euro 2 engines and low sulfur fuels instead of natural gas, will increase the maintenance and operating cost of the Transperth bus fleet by $9 769 per bus per annum. This is not correct, as the report uses erroneous information with respect to the Transperth fleet, thereby painting a more positive outcome for natural gas than exists in reality. To arrive at this additional cost, the Euro 2 and beyond review made incorrect judgments and assumptions including the following - (a) The assumed bus delivery is understated in the early years and overstated in the later years. Actual deliveries from DaimlerChrysler are public knowledge and are greater in the early years of the program and reduce as the program progresses. (b) It wrongly assumed all buses delivered under the 848 bus replacement program will be Euro 2. DaimlerChrysler will phase out the Euro 2 engines and commence delivery of Euro 3 engines in January 2003 when Australian design rule 80 becomes available for existing models. (c) The review panel estimated that an increase in fuel consumption of up to 25 per cent would occur as a result of the use of low sulfur fuel and the addition of airconditioning. Fuel consumption returned by the new bus fleet is better than expected. The actual average fuel consumption of the new diesel bus fleet is 42.27 litres per 100 kilometres, operating on a fuel with a sulfur content of 0.05 per cent, or 500 parts per million. Operators report that the introduction of this fuel has not resulted in an increase in the fuel consumption of the remainder of the older fleet. (d) The review panel has factored in exhaust after-treatment maintenance costs for Euro 2 and Euro 3 engines when all European manufacturers supplying public transport buses state that Euro 2 and Euro 3 standards can be achieved without any exhaust after-treatment. (e) The current Transperth buses being supplied under the bus purchase and supply agreement are fitted with oxidising catalysts that do not require maintenance and last the life of the bus. The Euro 2 and beyond review made reference to ultra fine particles, and criticised the ERG report because it ignored the health effects of these smaller particles. A subsequent literature search on this issue has confirmed that the total mass of particulate matter is significantly reduced with the introduction of low sulfur fuels; however, the number of ultra fine particles is increased. Research in this area to date is incomplete, and there is no general agreement on the definition of fine particles and the techniques used to measure them. Reduction of the sulfur content in diesel fuel results in a reduction in the emission of sulphate particles. This is an established fact. A lot of research is still to be undertaken on the health effects of these ultra fine particles. European engine manufacturers are developing exhaust after-treatments, such as continuously regenerating particulate traps and oxidising catalysts, for use with low sulfur fuels that result in significant reductions in emission. Further research is needed to determine the effect of these exhaust after-treatments on the production of ultrafine particles. Because diesel is the dominant fuel used in Europe and throughout the world for buses, a great deal of research is being carried out by engine manufacturers to resolve the issues surrounding ultrafine particles. It is believed that the ERG and beyond review is not a balanced view as it was published by the Australasian Natural Gas Vehicles Council, which has a vested interest in the outcome. (3) The Government will continue to implement the recommendations of the ERG report so that informed decisions can be made with respect to the use of gas as a transport fuel. To this end, Transport has purchased five gas buses as part of the bus purchase and supply agreement. The chassis and engines for three of these buses have arrived in Australia and Transport is negotiating with Advanced Engine Components Ltd to fit its NGVS 4 multipoint fuel injection system to these engines. The other two normally aspirated natural gas buses will be delivered in early 2001. These modified gas engines will be tested in an independent facility to gauge compliance with the Euro 3 European transient cycle and their performance assessed against DaimlerChrysler’s low emission diesel as well as the two gas buses to be delivered in early 2001. Transport will use the information from these trials in the review to be conducted in 2003.
Hon M.J. CRIDDLE replied: I thank the member for some notice of this question. (1) Yes, I am aware of the review. Almost two years have elapsed between the release of the ERG report and the recent Euro 2 and beyond review. During that time the goods and services tax, the diesel and alternative fuels grants scheme, the alternative fuels conversion program and the compressed natural gas infrastructure program have been introduced. All these programs have a significant impact on the economic evaluation carried out at the time the ERG report was published. (2) Making comparisons between the two reports is now irrelevant as the Euro 2 and beyond review uses all post-GST figures, whereas the ERG report acknowledged the proposed introduction of the GST but used pre-GST figures. The Euro 2 and beyond review indicated that the introduction of Euro 2 engines and low sulfur fuels instead of natural gas, will increase the maintenance and operating cost of the Transperth bus fleet by $9 769 per bus per annum. This is not correct, as the report uses erroneous information with respect to the Transperth fleet, thereby painting a more positive outcome for natural gas than exists in reality. To arrive at this additional cost, the Euro 2 and beyond review made incorrect judgments and assumptions including the following - (a) The assumed bus delivery is understated in the early years and overstated in the later years. Actual deliveries from DaimlerChrysler are public knowledge and are greater in the early years of the program and reduce as the program progresses. (b) It wrongly assumed all buses delivered under the 848 bus replacement program will be Euro 2. DaimlerChrysler will phase out the Euro 2 engines and commence delivery of Euro 3 engines in January 2003 when Australian design rule 80 becomes available for existing models. (c) The review panel estimated that an increase in fuel consumption of up to 25 per cent would occur as a result of the use of low sulfur fuel and the addition of airconditioning. Fuel consumption returned by the new bus fleet is better than expected. The actual average fuel consumption of the new diesel bus fleet is 42.27 litres per 100 kilometres, operating on a fuel with a sulfur content of 0.05 per cent, or 500 parts per million. Operators report that the introduction of this fuel has not resulted in an increase in the fuel consumption of the remainder of the older fleet. (d) The review panel has factored in exhaust after-treatment maintenance costs for Euro 2 and Euro 3 engines when all European manufacturers supplying public transport buses state that Euro 2 and Euro 3 standards can be achieved without any exhaust after-treatment. (e) The current Transperth buses being supplied under the bus purchase and supply agreement are fitted with oxidising catalysts that do not require maintenance and last the life of the bus. The Euro 2 and beyond review made reference to ultra fine particles, and criticised the ERG report because it ignored the health effects of these smaller particles. A subsequent literature search on this issue has confirmed that the total mass of particulate matter is significantly reduced with the introduction of low sulfur fuels; however, the number of ultra fine particles is increased. Research in this area to date is incomplete, and there is no general agreement on the definition of fine particles and the techniques used to measure them. Reduction of the sulfur content in diesel fuel results in a reduction in the emission of sulphate particles. This is an established fact. A lot of research is still to be undertaken on the health effects of these ultra fine particles. European engine manufacturers are developing exhaust after-treatments, such as continuously regenerating particulate traps and oxidising catalysts, for use with low sulfur fuels that result in significant reductions in emission. Further research is needed to determine the effect of these exhaust after-treatments on the production of ultrafine particles. Because diesel is the dominant fuel used in Europe and throughout the world for buses, a great deal of research is being carried out by engine manufacturers to resolve the issues surrounding ultrafine particles. It is believed that the ERG and beyond review is not a balanced view as it was published by the Australasian Natural Gas Vehicles Council, which has a vested interest in the outcome. (3) The Government will continue to implement the recommendations of the ERG report so that informed decisions can be made with respect to the use of gas as a transport fuel. To this end, Transport has purchased five gas buses as part of the bus purchase and supply agreement. The chassis and engines for three of these buses have arrived in Australia and Transport is negotiating with Advanced Engine Components Ltd to fit its NGVS 4 multipoint fuel injection system to these engines. The other two normally aspirated natural gas buses will be delivered in early 2001. These modified gas engines will be tested in an independent facility to gauge compliance with the Euro 3 European transient cycle and their performance assessed against DaimlerChrysler’s low emission diesel as well as the two gas buses to be delivered in early 2001. Transport will use the information from these trials in the review to be conducted in 2003.
I thank the member for some notice of this question. (1) Yes, I am aware of the review. Almost two years have elapsed between the release of the ERG report and the recent Euro 2 and beyond review. During that time the goods and services tax, the diesel and alternative fuels grants scheme, the alternative fuels conversion program and the compressed natural gas infrastructure program have been introduced. All these programs have a significant impact on the economic evaluation carried out at the time the ERG report was published. (2) Making comparisons between the two reports is now irrelevant as the Euro 2 and beyond review uses all post-GST figures, whereas the ERG report acknowledged the proposed introduction of the GST but used pre-GST figures. The Euro 2 and beyond review indicated that the introduction of Euro 2 engines and low sulfur fuels instead of natural gas, will increase the maintenance and operating cost of the Transperth bus fleet by $9 769 per bus per annum. This is not correct, as the report uses erroneous information with respect to the Transperth fleet, thereby painting a more positive outcome for natural gas than exists in reality. To arrive at this additional cost, the Euro 2 and beyond review made incorrect judgments and assumptions including the following - (a) The assumed bus delivery is understated in the early years and overstated in the later years. Actual deliveries from DaimlerChrysler are public knowledge and are greater in the early years of the program and reduce as the program progresses. (b) It wrongly assumed all buses delivered under the 848 bus replacement program will be Euro 2. DaimlerChrysler will phase out the Euro 2 engines and commence delivery of Euro 3 engines in January 2003 when Australian design rule 80 becomes available for existing models. (c) The review panel estimated that an increase in fuel consumption of up to 25 per cent would occur as a result of the use of low sulfur fuel and the addition of airconditioning. Fuel consumption returned by the new bus fleet is better than expected. The actual average fuel consumption of the new diesel bus fleet is 42.27 litres per 100 kilometres, operating on a fuel with a sulfur content of 0.05 per cent, or 500 parts per million. Operators report that the introduction of this fuel has not resulted in an increase in the fuel consumption of the remainder of the older fleet. (d) The review panel has factored in exhaust after-treatment maintenance costs for Euro 2 and Euro 3 engines when all European manufacturers supplying public transport buses state that Euro 2 and Euro 3 standards can be achieved without any exhaust after-treatment. (e) The current Transperth buses being supplied under the bus purchase and supply agreement are fitted with oxidising catalysts that do not require maintenance and last the life of the bus. The Euro 2 and beyond review made reference to ultra fine particles, and criticised the ERG report because it ignored the health effects of these smaller particles. A subsequent literature search on this issue has confirmed that the total mass of particulate matter is significantly reduced with the introduction of low sulfur fuels; however, the number of ultra fine particles is increased. Research in this area to date is incomplete, and there is no general agreement on the definition of fine particles and the techniques used to measure them. Reduction of the sulfur content in diesel fuel results in a reduction in the emission of sulphate particles. This is an established fact. A lot of research is still to be undertaken on the health effects of these ultra fine particles. European engine manufacturers are developing exhaust after-treatments, such as continuously regenerating particulate traps and oxidising catalysts, for use with low sulfur fuels that result in significant reductions in emission. Further research is needed to determine the effect of these exhaust after-treatments on the production of ultrafine particles. Because diesel is the dominant fuel used in Europe and throughout the world for buses, a great deal of research is being carried out by engine manufacturers to resolve the issues surrounding ultrafine particles. It is believed that the ERG and beyond review is not a balanced view as it was published by the Australasian Natural Gas Vehicles Council, which has a vested interest in the outcome. (3) The Government will continue to implement the recommendations of the ERG report so that informed decisions can be made with respect to the use of gas as a transport fuel. To this end, Transport has purchased five gas buses as part of the bus purchase and supply agreement. The chassis and engines for three of these buses have arrived in Australia and Transport is negotiating with Advanced Engine Components Ltd to fit its NGVS 4 multipoint fuel injection system to these engines. The other two normally aspirated natural gas buses will be delivered in early 2001. These modified gas engines will be tested in an independent facility to gauge compliance with the Euro 3 European transient cycle and their performance assessed against DaimlerChrysler’s low emission diesel as well as the two gas buses to be delivered in early 2001. Transport will use the information from these trials in the review to be conducted in 2003.
(1) Yes, I am aware of the review. Almost two years have elapsed between the release of the ERG report and the recent Euro 2 and beyond review. During that time the goods and services tax, the diesel and alternative fuels grants scheme, the alternative fuels conversion program and the compressed natural gas infrastructure program have been introduced. All these programs have a significant impact on the economic evaluation carried out at the time the ERG report was published. (2) Making comparisons between the two reports is now irrelevant as the Euro 2 and beyond review uses all post-GST figures, whereas the ERG report acknowledged the proposed introduction of the GST but used pre-GST figures. The Euro 2 and beyond review indicated that the introduction of Euro 2 engines and low sulfur fuels instead of natural gas, will increase the maintenance and operating cost of the Transperth bus fleet by $9 769 per bus per annum. This is not correct, as the report uses erroneous information with respect to the Transperth fleet, thereby painting a more positive outcome for natural gas than exists in reality. To arrive at this additional cost, the Euro 2 and beyond review made incorrect judgments and assumptions including the following - (a) The assumed bus delivery is understated in the early years and overstated in the later years. Actual deliveries from DaimlerChrysler are public knowledge and are greater in the early years of the program and reduce as the program progresses. (b) It wrongly assumed all buses delivered under the 848 bus replacement program will be Euro 2. DaimlerChrysler will phase out the Euro 2 engines and commence delivery of Euro 3 engines in January 2003 when Australian design rule 80 becomes available for existing models. (c) The review panel estimated that an increase in fuel consumption of up to 25 per cent would occur as a result of the use of low sulfur fuel and the addition of airconditioning. Fuel consumption returned by the new bus fleet is better than expected. The actual average fuel consumption of the new diesel bus fleet is 42.27 litres per 100 kilometres, operating on a fuel with a sulfur content of 0.05 per cent, or 500 parts per million. Operators report that the introduction of this fuel has not resulted in an increase in the fuel consumption of the remainder of the older fleet. (d) The review panel has factored in exhaust after-treatment maintenance costs for Euro 2 and Euro 3 engines when all European manufacturers supplying public transport buses state that Euro 2 and Euro 3 standards can be achieved without any exhaust after-treatment. (e) The current Transperth buses being supplied under the bus purchase and supply agreement are fitted with oxidising catalysts that do not require maintenance and last the life of the bus. The Euro 2 and beyond review made reference to ultra fine particles, and criticised the ERG report because it ignored the health effects of these smaller particles. A subsequent literature search on this issue has confirmed that the total mass of particulate matter is significantly reduced with the introduction of low sulfur fuels; however, the number of ultra fine particles is increased. Research in this area to date is incomplete, and there is no general agreement on the definition of fine particles and the techniques used to measure them. Reduction of the sulfur content in diesel fuel results in a reduction in the emission of sulphate particles. This is an established fact. A lot of research is still to be undertaken on the health effects of these ultra fine particles. European engine manufacturers are developing exhaust after-treatments, such as continuously regenerating particulate traps and oxidising catalysts, for use with low sulfur fuels that result in significant reductions in emission. Further research is needed to determine the effect of these exhaust after-treatments on the production of ultrafine particles. Because diesel is the dominant fuel used in Europe and throughout the world for buses, a great deal of research is being carried out by engine manufacturers to resolve the issues surrounding ultrafine particles. It is believed that the ERG and beyond review is not a balanced view as it was published by the Australasian Natural Gas Vehicles Council, which has a vested interest in the outcome. (3) The Government will continue to implement the recommendations of the ERG report so that informed decisions can be made with respect to the use of gas as a transport fuel. To this end, Transport has purchased five gas buses as part of the bus purchase and supply agreement. The chassis and engines for three of these buses have arrived in Australia and Transport is negotiating with Advanced Engine Components Ltd to fit its NGVS 4 multipoint fuel injection system to these engines. The other two normally aspirated natural gas buses will be delivered in early 2001. These modified gas engines will be tested in an independent facility to gauge compliance with the Euro 3 European transient cycle and their performance assessed against DaimlerChrysler’s low emission diesel as well as the two gas buses to be delivered in early 2001. Transport will use the information from these trials in the review to be conducted in 2003.
(2) Making comparisons between the two reports is now irrelevant as the Euro 2 and beyond review uses all post-GST figures, whereas the ERG report acknowledged the proposed introduction of the GST but used pre-GST figures. The Euro 2 and beyond review indicated that the introduction of Euro 2 engines and low sulfur fuels instead of natural gas, will increase the maintenance and operating cost of the Transperth bus fleet by $9 769 per bus per annum. This is not correct, as the report uses erroneous information with respect to the Transperth fleet, thereby painting a more positive outcome for natural gas than exists in reality. To arrive at this additional cost, the Euro 2 and beyond review made incorrect judgments and assumptions including the following - (a) The assumed bus delivery is understated in the early years and overstated in the later years. Actual deliveries from DaimlerChrysler are public knowledge and are greater in the early years of the program and reduce as the program progresses. (b) It wrongly assumed all buses delivered under the 848 bus replacement program will be Euro 2. DaimlerChrysler will phase out the Euro 2 engines and commence delivery of Euro 3 engines in January 2003 when Australian design rule 80 becomes available for existing models. (c) The review panel estimated that an increase in fuel consumption of up to 25 per cent would occur as a result of the use of low sulfur fuel and the addition of airconditioning. Fuel consumption returned by the new bus fleet is better than expected. The actual average fuel consumption of the new diesel bus fleet is 42.27 litres per 100 kilometres, operating on a fuel with a sulfur content of 0.05 per cent, or 500 parts per million. Operators report that the introduction of this fuel has not resulted in an increase in the fuel consumption of the remainder of the older fleet. (d) The review panel has factored in exhaust after-treatment maintenance costs for Euro 2 and Euro 3 engines when all European manufacturers supplying public transport buses state that Euro 2 and Euro 3 standards can be achieved without any exhaust after-treatment. (e) The current Transperth buses being supplied under the bus purchase and supply agreement are fitted with oxidising catalysts that do not require maintenance and last the life of the bus. The Euro 2 and beyond review made reference to ultra fine particles, and criticised the ERG report because it ignored the health effects of these smaller particles. A subsequent literature search on this issue has confirmed that the total mass of particulate matter is significantly reduced with the introduction of low sulfur fuels; however, the number of ultra fine particles is increased. Research in this area to date is incomplete, and there is no general agreement on the definition of fine particles and the techniques used to measure them. Reduction of the sulfur content in diesel fuel results in a reduction in the emission of sulphate particles. This is an established fact. A lot of research is still to be undertaken on the health effects of these ultra fine particles. European engine manufacturers are developing exhaust after-treatments, such as continuously regenerating particulate traps and oxidising catalysts, for use with low sulfur fuels that result in significant reductions in emission. Further research is needed to determine the effect of these exhaust after-treatments on the production of ultrafine particles. Because diesel is the dominant fuel used in Europe and throughout the world for buses, a great deal of research is being carried out by engine manufacturers to resolve the issues surrounding ultrafine particles. It is believed that the ERG and beyond review is not a balanced view as it was published by the Australasian Natural Gas Vehicles Council, which has a vested interest in the outcome. (3) The Government will continue to implement the recommendations of the ERG report so that informed decisions can be made with respect to the use of gas as a transport fuel. To this end, Transport has purchased five gas buses as part of the bus purchase and supply agreement. The chassis and engines for three of these buses have arrived in Australia and Transport is negotiating with Advanced Engine Components Ltd to fit its NGVS 4 multipoint fuel injection system to these engines. The other two normally aspirated natural gas buses will be delivered in early 2001. These modified gas engines will be tested in an independent facility to gauge compliance with the Euro 3 European transient cycle and their performance assessed against DaimlerChrysler’s low emission diesel as well as the two gas buses to be delivered in early 2001. Transport will use the information from these trials in the review to be conducted in 2003.
(a) The assumed bus delivery is understated in the early years and overstated in the later years. Actual deliveries from DaimlerChrysler are public knowledge and are greater in the early years of the program and reduce as the program progresses. (b) It wrongly assumed all buses delivered under the 848 bus replacement program will be Euro 2. DaimlerChrysler will phase out the Euro 2 engines and commence delivery of Euro 3 engines in January 2003 when Australian design rule 80 becomes available for existing models. (c) The review panel estimated that an increase in fuel consumption of up to 25 per cent would occur as a result of the use of low sulfur fuel and the addition of airconditioning. Fuel consumption returned by the new bus fleet is better than expected. The actual average fuel consumption of the new diesel bus fleet is 42.27 litres per 100 kilometres, operating on a fuel with a sulfur content of 0.05 per cent, or 500 parts per million. Operators report that the introduction of this fuel has not resulted in an increase in the fuel consumption of the remainder of the older fleet. (d) The review panel has factored in exhaust after-treatment maintenance costs for Euro 2 and Euro 3 engines when all European manufacturers supplying public transport buses state that Euro 2 and Euro 3 standards can be achieved without any exhaust after-treatment. (e) The current Transperth buses being supplied under the bus purchase and supply agreement are fitted with oxidising catalysts that do not require maintenance and last the life of the bus. The Euro 2 and beyond review made reference to ultra fine particles, and criticised the ERG report because it ignored the health effects of these smaller particles. A subsequent literature search on this issue has confirmed that the total mass of particulate matter is significantly reduced with the introduction of low sulfur fuels; however, the number of ultra fine particles is increased. Research in this area to date is incomplete, and there is no general agreement on the definition of fine particles and the techniques used to measure them. Reduction of the sulfur content in diesel fuel results in a reduction in the emission of sulphate particles. This is an established fact. A lot of research is still to be undertaken on the health effects of these ultra fine particles. European engine manufacturers are developing exhaust after-treatments, such as continuously regenerating particulate traps and oxidising catalysts, for use with low sulfur fuels that result in significant reductions in emission.
(b) It wrongly assumed all buses delivered under the 848 bus replacement program will be Euro 2. DaimlerChrysler will phase out the Euro 2 engines and commence delivery of Euro 3 engines in January 2003 when Australian design rule 80 becomes available for existing models. (c) The review panel estimated that an increase in fuel consumption of up to 25 per cent would occur as a result of the use of low sulfur fuel and the addition of airconditioning. Fuel consumption returned by the new bus fleet is better than expected. The actual average fuel consumption of the new diesel bus fleet is 42.27 litres per 100 kilometres, operating on a fuel with a sulfur content of 0.05 per cent, or 500 parts per million. Operators report that the introduction of this fuel has not resulted in an increase in the fuel consumption of the remainder of the older fleet. (d) The review panel has factored in exhaust after-treatment maintenance costs for Euro 2 and Euro 3 engines when all European manufacturers supplying public transport buses state that Euro 2 and Euro 3 standards can be achieved without any exhaust after-treatment. (e) The current Transperth buses being supplied under the bus purchase and supply agreement are fitted with oxidising catalysts that do not require maintenance and last the life of the bus. The Euro 2 and beyond review made reference to ultra fine particles, and criticised the ERG report because it ignored the health effects of these smaller particles. A subsequent literature search on this issue has confirmed that the total mass of particulate matter is significantly reduced with the introduction of low sulfur fuels; however, the number of ultra fine particles is increased. Research in this area to date is incomplete, and there is no general agreement on the definition of fine particles and the techniques used to measure them. Reduction of the sulfur content in diesel fuel results in a reduction in the emission of sulphate particles. This is an established fact. A lot of research is still to be undertaken on the health effects of these ultra fine particles. European engine manufacturers are developing exhaust after-treatments, such as continuously regenerating particulate traps and oxidising catalysts, for use with low sulfur fuels that result in significant reductions in emission.
(c) The review panel estimated that an increase in fuel consumption of up to 25 per cent would occur as a result of the use of low sulfur fuel and the addition of airconditioning. Fuel consumption returned by the new bus fleet is better than expected. The actual average fuel consumption of the new diesel bus fleet is 42.27 litres per 100 kilometres, operating on a fuel with a sulfur content of 0.05 per cent, or 500 parts per million. Operators report that the introduction of this fuel has not resulted in an increase in the fuel consumption of the remainder of the older fleet. (d) The review panel has factored in exhaust after-treatment maintenance costs for Euro 2 and Euro 3 engines when all European manufacturers supplying public transport buses state that Euro 2 and Euro 3 standards can be achieved without any exhaust after-treatment. (e) The current Transperth buses being supplied under the bus purchase and supply agreement are fitted with oxidising catalysts that do not require maintenance and last the life of the bus. The Euro 2 and beyond review made reference to ultra fine particles, and criticised the ERG report because it ignored the health effects of these smaller particles. A subsequent literature search on this issue has confirmed that the total mass of particulate matter is significantly reduced with the introduction of low sulfur fuels; however, the number of ultra fine particles is increased. Research in this area to date is incomplete, and there is no general agreement on the definition of fine particles and the techniques used to measure them. Reduction of the sulfur content in diesel fuel results in a reduction in the emission of sulphate particles. This is an established fact. A lot of research is still to be undertaken on the health effects of these ultra fine particles. European engine manufacturers are developing exhaust after-treatments, such as continuously regenerating particulate traps and oxidising catalysts, for use with low sulfur fuels that result in significant reductions in emission.
(d) The review panel has factored in exhaust after-treatment maintenance costs for Euro 2 and Euro 3 engines when all European manufacturers supplying public transport buses state that Euro 2 and Euro 3 standards can be achieved without any exhaust after-treatment. (e) The current Transperth buses being supplied under the bus purchase and supply agreement are fitted with oxidising catalysts that do not require maintenance and last the life of the bus. The Euro 2 and beyond review made reference to ultra fine particles, and criticised the ERG report because it ignored the health effects of these smaller particles. A subsequent literature search on this issue has confirmed that the total mass of particulate matter is significantly reduced with the introduction of low sulfur fuels; however, the number of ultra fine particles is increased. Research in this area to date is incomplete, and there is no general agreement on the definition of fine particles and the techniques used to measure them. Reduction of the sulfur content in diesel fuel results in a reduction in the emission of sulphate particles. This is an established fact. A lot of research is still to be undertaken on the health effects of these ultra fine particles. European engine manufacturers are developing exhaust after-treatments, such as continuously regenerating particulate traps and oxidising catalysts, for use with low sulfur fuels that result in significant reductions in emission.
(e) The current Transperth buses being supplied under the bus purchase and supply agreement are fitted with oxidising catalysts that do not require maintenance and last the life of the bus. The Euro 2 and beyond review made reference to ultra fine particles, and criticised the ERG report because it ignored the health effects of these smaller particles. A subsequent literature search on this issue has confirmed that the total mass of particulate matter is significantly reduced with the introduction of low sulfur fuels; however, the number of ultra fine particles is increased. Research in this area to date is incomplete, and there is no general agreement on the definition of fine particles and the techniques used to measure them. Reduction of the sulfur content in diesel fuel results in a reduction in the emission of sulphate particles. This is an established fact. A lot of research is still to be undertaken on the health effects of these ultra fine particles. European engine manufacturers are developing exhaust after-treatments, such as continuously regenerating particulate traps and oxidising catalysts, for use with low sulfur fuels that result in significant reductions in emission.
The Euro 2 and beyond review made reference to ultra fine particles, and criticised the ERG report because it ignored the health effects of these smaller particles. A subsequent literature search on this issue has confirmed that the total mass of particulate matter is significantly reduced with the introduction of low sulfur fuels; however, the number of ultra fine particles is increased. Research in this area to date is incomplete, and there is no general agreement on the definition of fine particles and the techniques used to measure them. Reduction of the sulfur content in diesel fuel results in a reduction in the emission of sulphate particles. This is an established fact. A lot of research is still to be undertaken on the health effects of these ultra fine particles. European engine manufacturers are developing exhaust after-treatments, such as continuously regenerating particulate traps and oxidising catalysts, for use with low sulfur fuels that result in significant reductions in emission.
European engine manufacturers are developing exhaust after-treatments, such as continuously regenerating particulate traps and oxidising catalysts, for use with low sulfur fuels that result in significant reductions in emission.
It is believed that the ERG and beyond review is not a balanced view as it was published by the Australasian Natural Gas Vehicles Council, which has a vested interest in the outcome. (3) The Government will continue to implement the recommendations of the ERG report so that informed decisions can be made with respect to the use of gas as a transport fuel. To this end, Transport has purchased five gas buses as part of the bus purchase and supply agreement. The chassis and engines for three of these buses have arrived in Australia and Transport is negotiating with Advanced Engine Components Ltd to fit its NGVS 4 multipoint fuel injection system to these engines. The other two normally aspirated natural gas buses will be delivered in early 2001. These modified gas engines will be tested in an independent facility to gauge compliance with the Euro 3 European transient cycle and their performance assessed against DaimlerChrysler’s low emission diesel as well as the two gas buses to be delivered in early 2001. Transport will use the information from these trials in the review to be conducted in 2003.
(3) The Government will continue to implement the recommendations of the ERG report so that informed decisions can be made with respect to the use of gas as a transport fuel. To this end, Transport has purchased five gas buses as part of the bus purchase and supply agreement. The chassis and engines for three of these buses have arrived in Australia and Transport is negotiating with Advanced Engine Components Ltd to fit its NGVS 4 multipoint fuel injection system to these engines. The other two normally aspirated natural gas buses will be delivered in early 2001. These modified gas engines will be tested in an independent facility to gauge compliance with the Euro 3 European transient cycle and their performance assessed against DaimlerChrysler’s low emission diesel as well as the two gas buses to be delivered in early 2001. Transport will use the information from these trials in the review to be conducted in 2003.
These modified gas engines will be tested in an independent facility to gauge compliance with the Euro 3 European transient cycle and their performance assessed against DaimlerChrysler’s low emission diesel as well as the two gas buses to be delivered in early 2001. Transport will use the information from these trials in the review to be conducted in 2003.
Explore WA Government Data
Search the full archive in the free dashboard, or query programmatically via API.
Explore more
Government Gazette
Appointments, regulatory notices, planning changes.
Hansard
Debates, questions, speeches and sentiment.
Tabled Papers
Reports and documents tabled in Parliament.
Committees
Committee profiles and recent reports.
Regulations
Subsidiary legislation with filters and summaries.
Bills
Proposed laws and parliamentary progress.
Acts
Current WA legislation and summaries.
Explanatory Memoranda
Bills with EMs (text/PDF) available.
Members
MP profiles, party breakdown and rankings.
Pollie Rankings
Data-driven rankings across 19 categories.
Amendment Chains
Track how schemes and regulations evolve over time.