Final Draft

A ROADMAP FOR REDUCING BLACK

CARBON FROM HEAVY DUTY DIESEL
VEHICLES AND ENGINES IN BANGLADESH

FINAL DRAFT

Dhaka, March 2015

Final Draft

Contents
page no.

Contents

02

List of Abbreviation

03

Executive Summary

04

1. Introduction

05

1.1 Rationale for low-sulfur diesel

06

1.2 Purpose of the Roadmap

07

1.3 Methodology for the development of the roadmap

08

2. Technical Aspects of Diesel Combustion and Emission

12

3. Emission Control Technologies for Diesel Engines

13

4. Effects of Fuel Quality on Diesel Emissions

14

5. Diesel Emissions: Bangladesh Scenario

15

6. Cost of Low Sulfur Diesel

20

7. Implications of Introducing Low-Sulfur Diesel (LSD)

20

8. Policy Framework: Roadmap Actions and Milestones

21

8.1 Overcoming economic barriers and creating incentives for LSD

21

deployment

8.2 Addressing non-economic barriers

21

9. Final Draft of the proposed road map

22

10. Milestones for introducing LSD

30

11. Conclusions

33

12. Future Plans

35

Appendix-A: Summary of meetings with focus groups and stakeholders 36

Appendix-B: First draft of the proposed road map

49

Appendix-C: Documents Provided by Stakeholders

53

Final Draft

LIST OF ABBREVIATIONS
BADC

Bangladesh Agricultural

ECD

Emission Control Devices

ERL

Eastern Refinery Ltd

Development Corporation
BPC

Bangladesh Petroleum
Corporation

BR

Bangladesh Railway

GOB

Government of Bangladesh

BRTC

Bangladesh Road Transport

HC

Hydro-Carbon

HSD

High Speed Diesel

HSFO

High Sulfur Fuel Oil

KPC

Kuwait Petroleum

Corporation
BSTI

Bangladesh Standards and

Testing Institute

BRTA

Bangladesh Road Transport

Authority

BIWTA

Bangladesh Inland Water

Transport Authority

BIWTC

Corporation

Bangladesh Inland Water

LSD

Low Sulfur Diesel

NOx

Nitrogen Oxides

Transport Corporation
BUET

Bangladesh University of
Engineering and Technology

CAA

Clean Air Asia

PDB

Power Development Board

CO

Carbon Monoxide

PM

Particulate Matter

CNG

Compressed Natural Gas

SOx

Sulfur Oxides

DPF

Diesel Particulate Filter

WHO

World Health Organization

DOE

Department of Environment

Final Draft

EXECUTIVE SUMMARY
As a developing country, in Bangladesh, the use of motorized vehicles has been increasing at
a faster rate which leads to environmental pollution especially in highly populated
metropolitan areas. One of the most hazardous of these pollutions is the particulate matter.
High sulfur content in diesel is partly responsible for particulate matter which is a major
pollutant from diesel vehicles. More importantly, the emissions from diesel engines make the
emission control devices like diesel oxidation catalyst, diesel particulate filter (DPF), etc.,
inactive when the engine runs with high sulfur diesel.
The Government of Bangladesh (GOB) has taken many initiatives to reduce pollution. In
Bangladesh, Department of Environment (DOE) in collaboration with Clean Air Asia (CAA)
has initiated a project titled Roadmap for Reducing Black Carbon from Heavy Duty Diesel
Vehicles and Engines in Bangladesh to achieve a pollution free environment within a certain
period of time. Department of Mechanical Engineering, Bangladesh University of
Engineering and Technology (BUET) provided the technical consultation to DOE for this
roadmap project.
The proposed roadmap has taken into consideration the views and feedbacks from all relevant
stakeholders through a series of meetings and discussions. This roadmap incorporated
milestones of lowering the sulfur content on imported diesel fuel from the current level of
2500ppm to a stricter level of 500ppm by 2016. Eventually, it is targeted to be as low as
350ppm by 2020 and 50ppm by 2023. The consultation team recognizes the technical,
economic and socio-political implications of pursuing stricter standards. It is also suggested
that proper co-ordination of activities like - standardization of measurement of sulfur content
in diesel, up-gradation of vehicle emission standard for low sulfur diesel and effective control
of fuel adulteration is essential to achieve the full benefit of using low sulfur diesel. The
process should be accompanied by a public awareness program to create a better
understanding regarding the use of low sulfur diesel among the end users. The report
suggested a strategy for Eastern Refinery Ltd (ERL), the only major local producer of fuel in
the country, to be able to cope up with such reduction on sulfur level in their diesel product.

Final Draft

1. INTRODUCTION
Environmental pollutions including air pollution have been increasing day by day in
Bangladesh. The use of motorized vehicles is increasing at a faster rate which leads to
environment pollution especially in highly populated metropolitan areas. One of the most
hazardous of these pollutions is the particulate matter or PM. High sulfur content in diesel is
partly responsible for particulate matter which is a major pollutant from diesel vehicles.
These emissions from diesel engines make the emission control devices like catalytic
converter, diesel particulate filter (DPF), etc., inactive when the engine runs with high sulfur
diesel.
A pollution free environment is the dream of all and the Government of Bangladesh (GOB)
has taken many initiatives to reduce pollution. In Bangladesh, Department of Environment
(DOE) in collaboration with Clean Air Asia (CAA) has initiated a project titled Roadmap
for Reducing Black Carbon from Heavy Duty Diesel Vehicles and Engines in Bangladesh to
achieve a pollution free environment within a certain period of time. Department of
Mechanical Engineering on behalf of the Bureau of Research, Testing and Consultation of
Bangladesh University of Engineering and Technology (BUET) has become the technical
consultant to DOE for this roadmap project. In this regard, a team of experts consisting of 5
members from the Department of Mechanical Engineering has been working on with an
ultimate goal of proposing a roadmap.
The specific objectives that are being fulfilled by this Consultation team are as follows:

i)

Department of Environment will arrange discussion meetings among the stakeholders

and the Consultant will gather the feedback for the proposed roadmap from these
stakeholders. The responsibility to invite the participants from government, private
sectors and civil societies to join the stakeholder groups lies with the DOE.

The stakeholders will express their views on the existing fuel / vehicle emission
standards in Bangladesh and sort out the barrier for implementing that. The possible
barrier for the proposed roadmap will also be highlighted and way out to solve /
overcome the barrier

will

be discussed. The shortcomings

of different

implementing/enforcing authorities will also be considered and the remedy

proposed.
5

will

be

Final Draft

ii)

The technical aspects for using high sulfur content diesel in vehicles and engines will
be highlighted by the Consultant to all the stakeholders so that they can contribute to
develop a roadmap for Low Sulfur Diesel (LSD).

iii)

The upcoming roadmap will be proposed by the Consultation group and will be
reviewed / modified in the stakeholders forum discussion meeting.

iv)

The Consultation team will also provide technical assistance for the up-gradation of
Eastern Refinery Ltd (ERL).

1.1 Rationale for Low-Sulfur Diesel

Pollutants are formed in diesel engines, which are very harmful for both environment and
human health. The major pollutants that are produced during the diesel combustion are
Particulate Matter (PM), Nitrogen Oxides (NOx), Unburnt Hydro-Carbon (HC), Sulfur
Oxides (SOx) and Carbon Monoxide (CO). Particulate matters from diesel engines consist of
primarily carbon particles, the remainders are hydrocarbon compounds (some of which are
bound to soot), and a few are sulfates in the form of aerosols. The adverse effects of pollution
from diesel engines are well known. SO2 is the principal and most ubiquitous urban air
pollutant which is a highly irritating gas, and at levels as low as 0.3 to 1.0 ppm it can be
identified by either smell or taste. The sulfate particulate matter (PM) is very much harmful
for human body especially for small children.

During breathing, small particles of diesel exhaust are drawn into the lungs. The microscopic
particles in diesel exhaust are less than one-fifth the thickness of a human hair and are small
enough to penetrate deep into the lungs, where they contribute to a range of health problems .
Headache, cancer, asthma, cardiovascular diseases, chronic obstructive pulmonary diseases,
diabetes and many other diseases might be caused from diesel pollutants. In 2012, the World
Health Organization (WHO) declared that diesel pollutants are carcinogenic. These pollutants
can also reduce visibility in the environment by creating smog. It may also be responsible for
acid rain.

Final Draft

To reduce pollutant emissions from diesel engines, a number of methods are available. Two
of the most important ones are to use emission control devices (ECD) and to use good quality
fuel. These two, however, are interlinked in such a way that one requires the use of the other.
Diesel emission control devices, such as, catalytic converters, DPF, etc. become inactive
when they come in contact with oxides of sulfur. Catalysts and other elements inside the
devices are covered by SOx thus losing its capability to convert the harmful gases to more
benign ones. In addition, sulfur compounds in the exhaust envelope PM making it larger
which ultimately clog the DPF.

At present, the upper limit of sulfur content in diesel fuel in Bangladesh is 2500 ppm (0.25%
v/v). However, many stakeholders claim that the actual level at the end-users is much higher.
As a result, recently imported vehicles which are fitted with ECD face a number of technical
problems running with high-speed diesel (HSD). In most such cases, the ECD are removed
from the vehicle thus contributing to pollutant emissions like the older generation vehicles.

The main impact of using low sulfur diesel is on the emission reduction capability of the
post-engine emission control devices like catalytic converter, diesel particulate filter (DPF),
etc., which are incorporated in the exhaust system of modern diesel engines.

1.2 Purpose of the Roadmap

Diesel engine vehicles running in and around Dhaka city contribute to pollutant emissions
into the atmosphere. So reducing sulfur content from the current 2500 ppm down to 500 or
even to 50 ppm will indeed have a considerable effect on the air quality of the Dhaka city. In
this case, some locality in the immediate vicinity of the vehicles (roadside gatherings /
inhabitants) will have some immediate benefits out of this. In the long run, the entire city air
will get the benefits from the reduced sulfur content in diesel engines and vehicles.

Moreover, from technical point of view, 2-3 years down the road, most of the diesel engines
and vehicles will have ECD and demand low sulfur diesel for their proactive operation. In
that case, if we do not take necessary steps now to gradually reduce the sulfur content of
diesel, then the new diesel vehicles will face major challenges running on roads. To avoid
such situation, reduction in sulfur content in diesel is necessary.

Final Draft

With a view to reducing high sulfur content in diesel, a roadmap with relevant guidelines
have been proposed here by considering the views expressed and data collected from
different stakeholders during focus group meetings (FGMs) and keeping in mind the socioeconomic condition of the country.

1.3 Methodology for the development of the Roadmap

In order to formulate a draft roadmap for developing low sulfur diesel and clean vehicle
emissions policies in Bangladesh, the following activities have been carried out by the
Consultant (BUET):
(a)

Organization of bi-monthly stakeholder meetings in Bangladesh to provide forum for

stakeholder consultation. DOE invited participants from the government, private
sectors and civil societies to join the national stakeholders meetings. The stakeholder
groups were invited so as to:
i. Discuss and package the benefits of low sulfur diesel and clean vehicle
emissions for Bangladesh.
ii. Conduct a thorough review of existing national regulations, emission
standards, barriers for implementing the previous roadmap for clean fuels and
vehicles, incentives that might promote low sulfur fuel and clean vehicle
emissions in Bangladesh, assist funding for setting up desulfurization unit in
Eastern Refinery Limited.
iii. In addition to the national stakeholders meetings, the Consultants had 5 (five)
Focus group discussion (FGD) meetings that are listed in Table 1.

(b)

In the stakeholders meetings, the participants were given a set of questions relevant to
their interests. The Consultants recorded their comments during these meetings. The
summary of these meetings are reported in Appendix-A.

(c)

Evaluation of the benefits of low sulfur fuel and clean vehicle emissions standards for
Bangladesh.

(d)

Review of the existing Bangladesh national regulations and incentives that would
promote low sulfur fuel and cleaner vehicle emissions in Bangladesh e.g., on
emission, inspection of fuels and vehicles, catalytic converters, taxation regimes etc.

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Table 1: Stakeholders Participating in the Focus Group Discussion Meetings (FGDs):

Activities/Meeting

Time / Date

All Stakeholders Meeting-1

May 28, 2013

All Stakeholders

All Stakeholders Meeting-2

July 29, 2013

All Stakeholders

Focus Group Meeting-1

August 04,

(in Chittagong)

2013

Focus Group Meeting -2

Focus Group Meeting -3

ERL, BPC and all other oil distribution

companies of the country.
End-user stakeholders , i.e., Vehicle Owners

October 23,

Association, Vehicle Traders Association ,

2013

Vehicle Importers Association, etc.

January 15,

BRTA, BSTI, DOE, Traffic Authority,

2014

Focus Group Meeting -4

Participants

Dhaka Development Authority, etc.

Fuel Pump Owners' Association, DOE,

February 25,

Generator Importers' Association, Private

2014

Sector Power Plant Companies, etc.

DoE, Clean Air Asia (CAA), Vehicle

Mid-Term Report

Importer

Presentation
09 April, 2014

Association,

Communication

Ministry, BSTI, Ministry of Energy and

Mineral Resources, Science Laboratory and
Bus-Truck Owner Association.
DoE,

Focus Group Meeting-5

25 June, 2014

BADC,

Communication

BSTI,

BRTC,

Ministry,

ERL,

Ministry

of

Energy and Mineral Resources.

DoE, BADC, BSTI, ERL, Ministry of
2nd National Stakeholder

29 October,

Meeting

2014

Energy and Mineral

Owners'

Association

Resources,
and

Petrol

Truck
Pump

Owners' Association
DoE, Clean Air Asia, BRTA, BSTI, BPC,
ERL, Ministry of Energy and Mineral
3rd (Final) National

14 January

Stakeholder Meeting

2015

Resources,

Ministry

of

Industries,

Bangladesh Railway, BCSIR , Vehicle

Importers' Association.

Final Draft

Analysis of Feedback from FGDs and Stakeholders Meetings:

From the deliberations with the stakeholders, the consultant team (BUET) was informed
that of the total demand of diesel in the country, about 15% is produced by the ERL
which is about 0.4 million tons per year and the rest 85% is imported from abroad. From
the trend analysis of the given data the same was found to be true.

The ppm content of sulfur in diesel produced by the ERL is around 5000 ppm and the
ppm content of the imported diesel is around 2000 ppm. Thus when these two are
blended, the resultant blend is around 2500 ppm. Since the ERL's diesel contains very
high sulfur content, so even importing diesel with zero ppm sulfur cannot produce a
blend of less than 500 ppm sulfur if the ERL production (15%) and import (85%)
percentage remains the same. So blending is impractical in case of the necessity of
reducing the sulfur content below a certain level. Table-2 summarizes the situation.

It was also revealed that ERL proposed a capacity expansion of further 3.0 million tons of
crude oil in addition to the existing 1.5 million tons. That would increase the production
of diesel up to 1.2 million tons. Keeping in mind that the demand for diesel has been
increasing at the rate of about 0.1 million tons per year especially in the transport sector,
by the time that the project is materialized, the share of ERL in the diesel market will be
somewhere between 30 and 40 percent. ERL also proposed a 1.4 million ton
desulfurization unit which will be able to produce 350 ppm sulfur diesel. This level does
not seem to be a prudent one. Such a plant should have an economic life of at least 25
years. It is quite likely that within about 10 to 15 years time, most of the other countries
will set the sulfur content at 10 ppm at most (developed countries have already set the
standard at 10 ppm and advancing towards 0 ppm in the very near future). Therefore,
ERL should revise their proposal to set the sulfur level to 0 ppm or 10 ppm at most for
their proposed desulfurization plant.

The additional costs that will be incurred in case of import of 500 ppm sulfur diesel
instead of 2000 ppm sulfur diesel is substantially low. Considering the huge benefits that
will be gained in the form of clean atmosphere, reduced health cost, increased vehicle life
and others, this additional cost seems quite reasonable.

So instead of distributing it to the transportation sector, all the diesel produced by the
ERL should be channeled to limited sectors such as remote power plants, marine vehicles,
industries, etc. which are far from the cities. For the transport sector, 100% directly
imported diesel of the required amount (500/350/50 ppm) sulfur content according to the
proposed roadmap should be distributed.
10

Final Draft

Some of the nations such as China and India setup a split standard for their metros (with
lower allowable ppm level) and other regions (with higher allowable ppm level). From
the discussion with the stakeholders, it was revealed that two separate standards are not
feasible for a small country like Bangladesh. There are cross-country travels and logistic
and administrative shortcomings related to the marketing, distribution, and storage of
fuels of two different standards.

On the other hand, from the deliberations with the stakeholders, it was observed that all
these efforts for reducing sulfur in fuel will not be fruitful unless we can control
adulteration of diesel fuel. Such adulterations were reported to have been taking place at
various stages such as during lighterage from marine vessels, at the storage depot, tank
lorries and at various distribution channels. In such cases, post-engine emission control
devices cannot be operated effectively and people will be deprived of clean air despite
buying expensive vehicles as well as fuels. So, some definitive measures must be taken to
control these adulteration processes. Continuous monitoring of the various processes and
channels by the concerned authorities, law enforcements through exemplary punishments,
introduction of anti-adulteration technical measures, and measurement of fuel properties
to indicate the extent of adulteration are the few steps that can be implemented to control
adulteration.

It was felt mandatory to set a standard methodology to measure sulfur content and other
fuel properties so that no controversy arises from the measurement process. At present,
there is a lack of coordination between the concerned parties like ERL, BSTI, and DoE,
regarding such methodologies. Experiences and technologies from the neighboring and/or
developed countries can be adopted to set up such measuring and monitoring
stations/authorities.

Effect of emission from HSFO-run power plants and coal-based brick-fields situated in
and around Dhaka city may have a significant role on the resulting sulfur content in the
air. However, the team does not have enough data to quantitatively assess their
contribution of sulfur pollution in the air of Dhaka city. If their sulfur pollution is at a
significant level this may outweigh the benefits of using low sulfur diesel in vehicles.

11

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2. TECHNICAL ASPECTS OF DIESEL COMBUSTION AND EMISSION

The particles from diesel engines consist of hydrocarbon particles, the remainders are
hydrocarbon compounds (some of which are bound to soot), and a few are sulfates in the
form of aerosols. The creation of soot is largely determined by the local temperature (800
1400 K) and the oxygen concentration, and occurs in two phases. The

reactions

in

the

primary formation phase occur almost exclusively from radical chain mechanisms in the core
of the fuel jet behind the jet tips O, H, and OH radicals are formed. Cyclic and polycyclic
aromatic hydrocarbons (PAH) form by polymerization and cyclization. Uncombusted and
partially combusted hydrocarbons, especially aldehydes can bond to the secondary particles
due to their large specific surface. As combustion proceeds, the secondary formation phase is
soot reoxidation that is governed by the dwell time and oxygen concentration. The diameter
of the particles varies between 1 and 1000 nm. For homogeneous mixtures, soot is found in
the exhaust emissions when the mixture is very rich (50% of theoretical air); at more than
60% air under optimum conditions, there is no demonstrable soot formation. Important
unrestricted components in untreated exhaust from diesel engines are cyanide, ammonia
(NH3), sulfur dioxide (SO2), and sulfates. Specifically, hydrocarbons, methane, ethane,
ethene, ethine, benzene, and toluene are of particular interest.

The adverse effects of pollution from diesel engines are well known. SO2 is the principal and
most ubiquitous urban air pollutant which is a highly irritating gas, and at levels as low as 0.3
to 1.0 ppm it can be identified by either smell or taste. Because of its marked solubility in
water, it is almost 100 percent absorbed in the upper airways in human beings. Even a mild
exposure (6 to 12 ppm) can cause serious respiratory and related troubles. Similar
phenomenon can result from chronic irritation by other pollutants such as NO2 and O3. An
intense exposure to SO2 may lead to laryngeal spasm or pulmonary edema, both of which
conditions could be fatal. Sulfate ions in different substances vary widely in their irritant
potency. The sulfate ion itself is not an irritant. The most potent agent is sulfuric acid
(H2SO4), followed by ferric sulfate, zinc sulfate, and ammonium sulfate.

12

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3. EMISSION CONTROL TECHNOLOGIES FOR DIESEL ENGINES

Pollution from diesel engines can be controlled in different ways; some are performed before
the combustion of diesel and some after the diesel combustion. The devices which are
employed before combustion is called pre-ignition devices and devices that are used after the
combustion is called post-ignition devices.
Pre-ignition devices: Hot air-intake system and improved fuel metering electronic
governor.
In-Engine systems: (i) Direct and indirect fuel injection, injection retardation (ii) Valve
design - Vtech, 16 Valve, DOHC (iii) EGR: Exhaust Gas Recirculation and (iv) Stratified
charge combustion, lean burn
Post-ignition devices:
(i) Diesel Particulate Filter (DPF): Diesel particulate filters (DPF) reduce diesel PM
emissions through filtration. This technology is very efficient in controlling diesel PM
emissions, and has been demonstrated to reduce diesel PM by over 90 percent.
(ii) Diesel Oxidation Catalyst (DOC): Diesel oxidation catalyst (DOC) reduces the emissions
of particulate matter (PM), carbon monoxide (CO) and gaseous reactive organic gas
(ROG) from diesel engines by catalytic oxidation.
(iii) Continuously Regenerative Trap (CRT): The CRT system utilizes a ceramic wall-flow
filter to trap particulates. The trapped particulate matter is continuously oxidized by
nitrogen dioxide generated in an oxidation catalyst which is placed upstream of the filter.
The CRT requires ultra low sulfur fuel and a certain minimum NOx/PM ratio for proper
operation.
(iv) Selective Catalytic Reduction (SCR): Selective Catalytic Reduction (SCR) is an
advanced active emissions control technology system that injects a liquid-reductant agent
through a special catalyst into the exhaust stream of a diesel engine. The reductant source
is usually automotive-grade urea, otherwise known as Diesel Exhaust Fluid (DEF). The
DEF sets off a chemical reaction that converts nitrogen oxides into nitrogen, water and
tiny amounts of carbon dioxide (CO2), natural components of the air we breathe, which is
then expelled through the vehicle tailpipe.

13

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4. EFFECTS OF FUEL QUALITY ON DIESEL EMISSIONS

The minimum requirements for diesel fuel are primarily concern density, ignition quality
(cetane number), boiling curve, resistance to cold, and sulfur content. Petroleum naturally
contains sulfur depending on where it comes from. The sulfur is chemically bound, and more
than 95% is converted into gaseous sulfur dioxide upon combustion the remainder largely
passes into the particle mass of the exhaust that contains sulfurous acids and sulfates leading
to corrosion and exhaust pollution. In addition to the soot in diesel exhaust that is suspected
of being carcinogenic, there are also polycyclic aromatic hydrocarbons (PAH). Local rich
conditions during combustion lead (via the intermediate steps of acetyls and polycyclic
hydrocarbons) to the formation of graphite-like soot particles. By means of coagulation and
agglomeration processes, soot particles approximately 100 to 300 nm in diameter (median)
arise from these approximately 110 nm (1 nm = 10-9 m) primary particles. Since the large
surface area (up to 200 m2/g) of these particles make them strongly adsorbent, a large share
(greater than 50% by weight) of hydrocarbons, sulfates, water, and lubricating oil
components can be demonstrated in diesel soot in addition to carbon. One known method for
reducing the total emission levels of particulate matter (TPM) from diesel engines is to use
low-sulfur (0.05 percent by weight, equivalent to 500 ppm) diesel fuel. The stringency of
legal restrictions on fuel sulfur has rapidly been tightened in recent years and continues to
tighten still (although, from one country to another, there may be field issues for some time).
The main reason for enforcing the use of low-sulfur diesel is that sulfur causes havoc in
emission control systems.

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5. DIESEL EMISSIONS: BANGLADESH SCENARIO

Bangladesh is an oil-importing country. The only refinery in the country is the Eastern
Refinery Limited (ERL) located in Chittagong. It has a capacity to handle 1.5 million tons of
crude oil per year. The major petroleum products are high-speed diesel (HSD) and highsulfur fuel oil (HSFO), constituting more than three-fourths of their production. The sulfur
content in HSD and HSFO are 0.5% (5000 ppm) and 3.5% (35,000 ppm) respectively.
However, the volume of HSD produced in ERL is relatively small and can meet only about
15 percent of the total national diesel demand of the country. In order to meet this
requirement, the controlling agency of ERL, Bangladesh Petroleum Corporation (BPC)
imports the remaining 85 percent through ERL from different countries. A FGM with BPC
and ERL revealed that the finished product, viz., HSD is important from Kuwait Petroleum
Corporation (KPC) which has a sulphur content of about 2000 ppm. HSD imported from
other sources have sulfur content of 2500 ppm. The current practice of ERL is to blend the
imported HSD from KPC with their own product to deliver HSD for country-wide
consumption with sulfur content of 2500 ppm.
The current emission regulations regarding diesel vehicles allow import of vehicles
complying EURO2 standard (for Dhaka and Chittagong) and EURO1 standard (for the rest of
the country) and the free acceleration smoke density limit is 40 HSU (k = 1.2 m -1) for
naturally aspirated and 61 HSU (k = 2.2 m-1) for turbo-charged diesel engines.
The data related to the production, consumption and import are gathered from various sources
Consumption
HSD during 2012-13
and are presented inSector-wise
the following
figures and of
tables.
1

Domestic and others Power

1%

Communication

4%
7%

Industry

Agriculture
33%

55%

Fig. 1: Sector-wise consumption of HSD in Bangladesh (2012-13)

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Sector-wise Consumption of HSD during Last 05 Years

1800000

Power

Industry

Agriculture

Communication

Domestic and Others

1600000
Consumption (MT)

1400000
1200000
1000000
800000
600000
400000
200000
0
2008-09

2009-10

2010-11
Years

2011-12

2012-13

Fig. 2: Consumption (sector-wise) of HSD (last 5 years)

Actual Sales of Fuel Oil Handling System (FOHS) during Last 10 Years
1200000

1000000

Sales in MT

800000

600000

400000

200000

0
2003-04 2004-05 2005-06 2006-07 2007-08 2008-09 2009-10 2010-11 2011-12 2012-13

Years

Fig. 3: Actual sales of High Sulfur Fuel Oil (last 10 years)

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Actual Sales of High Speed Diesel (HSD) during Last 10 Years

3500000
3000000

Sales in MT

2500000
2000000
1500000
1000000
500000
0
2003-04 2004-05 2005-06 2006-07 2007-08 2008-09 2009-10 2010-11 2011-12 2012-13

Years

Fig. 4: Actual Sales of High Speed Diesel (HSD) (last 10 years)

HSD Production by ERL, Consumption and Import

3500000
3000000

88.4%

2500000

87.1%
85.6%

2000000

MT

88.5%

89.3% of consumption
1500000

Production by ERL

Total Consumption

1000000

Import

500000
0
1

2008-09

1. 5

2009-10

2. 5

3. 5

2010-11

2011-12

4. 5

2012-13

Year

Fig. 5: HSD production and import by ERL (total consumption)

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A hypothetical analysis was done with the resulting sulfur content in diesel if the imported
diesel is blended with that produced by ERL, as shown in Table 2.

Table 2: Sulfur ppm after blending of imported and ERL produced HSD

Sulfur ppm in ERL produced

HSD (ERL production is about
15% of country demand)

Sulfur ppm in imported HSD (import is

about 85% of country demand)

Sulfur ppm
after
blending

5000

2000 (from KPC) [at present]

2450

5000

2500 (from other source) [at present]

2875

5000

500 [in future]

1175

5000

50 [in future]

793

5000

0 [assumption]

750

Table 2 clearly indicates that at present, ERL can deliver HSD with

2450 ppm sulfur

after blending (which is less than 2500 ppm, the country standard) only from the imported
HSD of KPC (which has about 2000 ppm of sulfur). In case of import from other sources
(2500 ppm), after blending, it does not meet the present standard. It also indicates that
importing HSD with 0 ppm sulfur and after blending with 5000 ppm of ERL produced HSD,
the value of sulfur ppm below 750 cannot be achieved.

Therefore, if the road map is set for 500 ppm in the near future, the blending of imported
HSD with that produced by ERL will not be compatible with the roadmap. In such cases,
HSD produced by ERL can have restricted uses in power plants in remote areas, marine
transports, or country-side irrigation, while the imported low sulfur diesel (LSD) can be used
in urban transports and other uses. In order to increase their share in the HSD market, ERL
proposed for a second Crude Processing Unit with an installed capacity of 3.0 million tons
per year along with a desulfurization plant (350 ppm) of a capacity of 1.4 million tons. That
means that had the proposed plant come into existence, ERL will be able to produce about 1.9
million tons of HSD against the present demand of around 3.0 million tons.

However, it is highly likely that by the time the proposed project is completed, the demand
for HSD will increase to about 3.7 million tons. That is, the country will need to import more
than half the total demand.
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Final Draft

In the discussion meetings, many stakeholders voiced their concern about the adulteration of
fuel (including diesel) in different stages of handling (from port up to the end user i.e., the
vehicle users). They believe that there is a widespread adulteration of fuels and they finally
recommended that all the concerned authorities should be accountable. They emphasized that
without proper control of adulteration at field level, all the efforts for reducing pollution by
improvement of fuel quality may prove fruitless.

Sulfur (from HSD) Scenario in Bangladesh and around Dhaka City

In the whole country:
Sulfur content in HSD in Bangladesh is about 2500 ppm. The total consumption of HSD in
2012-13 year in Bangladesh in power, industry, communication, domestic and other sectors is
29,64,604 MT which produced 7,412 MT of sulfur or sulfur compounds in Bangladesh from
HSD.

In and around Dhaka City:

In 2012-13, the consumption of HSD in Bangladesh in the whole communication sector was
16,21,675 MT.

Considering 90% of the diesel vehicles was used in 4 major cities (Dhaka, Chittagong,
Khulna and Rajshahi) and 50 % of which can be assumed to be running in Dhaka region only.

Again assuming 40% of the diesel vehicles of Dhaka region were used in and around Dhaka
city at a time, they produced sulfur amounting to about 730 MT in 2012-13 in and around
Dhaka city.

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6. COST OF LOW SULFUR DIESEL

Cost of diesel fuel includes among others, the price of crude oil, costs of refining,
distribution, marketing and taxes. In the US market, the price of crude oil and refining
constitute about 70% of the total cost. The pump price of ultra-low sulfur diesel (ULSD)) (015 ppm sulfur) is about US$ 1 per litre (*Source: www.eia.gov) over the last four years or so.
It is interesting to note that the cost of producing diesel is generally higher than that of
gasoline.

In Bangladesh, until recently the cost of diesel production was higher than the pump price.
But, the Government of Bangladesh, since inception, had been subsidizing the price of diesel
to facilitate the various economic sectors, especially, the farmers and in general, the
population. While the price of fuel in many developed countries are driven by market forces,
that in Bangladesh and some other countries are fixed by the Government.

The authors are unaware about any detailed study on the cost of LSD in Bangladesh market.
Verbal communications in one of the FGDs, it was revealed that the pump price of diesel
may go up by about Tk. 4 to Tk. 5 per liter. This may increase the cost associated with diesel
import in the order of taka 1500 crore per year. Thus, before commenting on the price of
ULSD, a proper study on the production and marketing costs needs to be accomplished.

7. IMPLICATIONS OF INTRODUCING LOW-SULFUR DIESEL (LSD)

The implications of introducing LSD in Bangladesh are many. A few of the important ones
are namely, technical, economic, and political. Technical advantages and disadvantages of
introducing LSD in Bangladesh with larger population of older vehicles in the diesel-driven
fleet have already been discussed in sufficient details in earlier sections. Economic
implications are wide ranging. From the past experiences, one can easily conclude that there
is a direct correlation of prices of essentials and other commodities and services with the
price of fuel. If the latter increases, all other prices go up almost immediately before the
market stabilizes.

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Final Draft

Political implications are tied up with the economic ones. Any increase in the price of fuels
causes an uproar in political arena. However, if adequate and effective measures are taken by
the various functionaries of the Government to make people aware of the bad effects of highsulfur diesel on human health and environment as well as the benefits of using LSD are
highlighted, the dissenting voices would not be too vocal.

8. POLICY FRAMEWORK: ROADMAP ACTIONS AND MILESTONES

8.1 Overcoming Economic Barriers and Creating Incentives for LSD Deployment

As discussed in the previous section, the immediate effect of rise in fuel prices is that the
transport costs of all forms go up. This in effect put an adverse effect on the economy as a
whole. Two propositions can be thought of in this regard. Firstly, the Government, for the
sake of betterment of the environment, can continue giving subsidies for the first three years
which would be decreased gradually over this period. This would help ease the burden on the
people. Secondly, the Government can take up an aggressive public awareness program to
drum up the good effects of using LSD in regard to health and environment for the period
from now up to the deployment of LSD; i.e., in the period put forward in the proposed
roadmap. Then the stakeholders can prepare themselves for the increase in LSD price well in
advance.

Other incentives like reduced taxation for using LSD and importing of LSD vehicles,
imposing higher tax and duties for higher emission vehicles, etc., may also be implemented.

8.2 Addressing Non-Economic Barriers

Non-economic constraints are generally more difficult to handle than economic barriers. The
leaders of the country have to be proactive to motivate people in such a manner so that the
majority may feel that the introduction of LSD is necessary. A similar model of replacing
two-stroke three-wheelers in Dhaka and Chittagong with less polluting CNG driven threewheelers may be put to use.

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9. FINAL DRAFT OF THE PROPOSED ROADMAP

The first draft of the proposed roadmap was placed in a meeting with all the major
stakeholders, for their feedback. The draft had two options in the proposed roadmap,
which were discussed in detail (as included in Appendix-B). From the discussions with
stakeholders a number of interesting features and new findings were revealed

The process of importing low sulfur diesel would require some lead time for
acquiring diesel purchase from international suppliers. Refineries which typically
supply diesel to Bangladesh are having their up-gradations to produce low sulfur
diesel as well. Ministry of Energy and Mineral Resources, BPC and ERL are the
major stakeholders in this process.

The standardization of the procedure for measurement of sulfur content in diesel is

not completed yet in Bangladesh. The process also needed further acceptable
coordination among relevant government agencies. DoE, BSTI, ERL and BPC are
the major stakeholders in this process.

The modernization and establishment of desulphurization plant in ERL will require

a minimum lead time of three years before it could come into operation. Such
process may start in 2015 and currently targeted for achieving 350 ppm level. 350
ppm appears to be a low level of requirement based on the fact that 50 ppm diesel
will be standard within the life time of such renovations of ERL. Provision of
further improvement of low sulfur diesel must be included in the renovation plan of
ERL. Ministry of Energy and Mineral Resources, Ministry of Finance and ERL are
the major stakeholders in this process.

The production of diesel from ERL could not be stopped as it also produces HSFO,
octane, petrol, kerosene and a number of other products which are used as raw
materials in different industries. Possible internal markets where ERL diesel could
be separately channeled without blending with imported diesel were explored. At
first agriculture, power generation, inland water transport and railway have been
considered. Feedback from concerned stakeholders revealed a number of
limitations in this regard.
(i). Irrigation in agriculture uses sufficient amount (33%, i. e., more than a million
ton per year) of diesel and the existing engines can use diesel with higher
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Final Draft

sulfur content, but there is no separate distribution channel for such diesel.
Farmers use the same diesel as transportation and receive some financial subsidies
from the government. The demand for diesel varies seasonally and introducing a
cheaper diesel could also increase the possibility of widespread fuel adulteration.
This did not appear to be a prospective sector.
(ii). Power plants using diesel fuel could be a viable option of using ERL diesel.
Diesel used in this sector is about 7% of the national demand which is more than
0.22 million tons per year. However, most of the diesel power plants are owned by
private sectors and they already have their agreement of fuel import/supply in
practice, in which case they may not be interested of changing. This appears to be
a good prospective sector.
(iii). Railway uses small amount of diesel only, reaching about 31,000 tons per year.
With is own distribution network, this appears to be a good prospective sector.
(iv). Inland water transports use a significant part of diesel used in transportation
sector. A large portion of water transport is owned by private vessel owners who
purchase diesel from the same market as road transportation. The portion of diesel
used by vessels owned by government agencies like BIWTC, BIWTA etc.
amounts to a small fraction of only about 13,000 tons per year. This appears to be
a prospective sector.
Table 3 shows a possible list of restricted clients which may be selected for marketing the
diesel produced by ERL. (Estimations are based on the trend of the last 5 years.)
Table 3: Proposed list of consumers for diesel produced by ERL
ERL diesel production
tons per year

350,000 400,000

Restricted clients

Clients expected demand

tons per year

Diesel Power Plants

2,50,000 300,000

Bangladesh Railway

30,000 40,000

Inland water Transport (Govt

Sector)

15,000 20,000

Inland water Transport /

Industry
(Private Sectors, around ERL)

50,000

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The control of fuel adulteration is essential for getting the real environmental benefit
of using low sulfur diesel and modern diesel engines fitted with post-ignition emission
control devices, both of which involve additional costs. Mixing of fluids like
condensates, used hydrocarbon chemicals and water were reported to adulterate diesel
fuel. Presence of such materials would significantly affect engine emissions and
outweigh the benefit of using low sulfur diesel. These practices have been going on
for a long period of time and involve a number of levels in the distribution channel in
Bangladesh. Taking sufficient measures for the monitoring, implementing law
enforcements and ensuring good coordination of relevant government agencies are
essential to control this problem. Ministry of Energy and Mineral Resources, Ministry
of Home Affairs, BPC and ERL are the major stakeholders in this process.

The emission regulation for diesel vehicles and engines should be updated in
conjunction with the availability of low sulfur fuel. As fuel below 500 ppm level
becomes available in the local market, importing new vehicles and engines only with
diesel emission control technologies must be made mandatory. It may take few years
for the changeover of the fleet to better technology, but since old engines can run on
low sulfur diesel there is no need to maintain a separate supply line for existing
vehicles and engines. In metropolitan cities, the use of CNG in public transport sector
may continue and in case of new diesel vehicles, use of low sulfur diesel and vehicles
fitted with post-ignition emission control devices must be made mandatory. DoE,
Ministry of Commerce and BRTA are the major stakeholders in this process.

The feedback from stakeholders and analyses of the information reveal that a number of
activities need to be synchronized to achieve a realistic and fruitful roadmap for sulfur
reduction in diesel fuel. Solving the problems associated with the high sulfur diesel
currently produced at ERL needs a multiple strategy plan to be implemented. Reducing
sulfur in diesel will definitely involve more cost, but this needs to be weighed against
health benefits and longer engine life. A gradual change is more pragmatic based on the
socio-economic and technical scenario of Bangladesh, but the whole process can not wait
indefinitely for preparation of all the components. Based on the features stated above, the
proposed roadmap for developing low sulfur diesel fuel and clean vehicle emissions
policies in Bangladesh is framed as follows:

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Final Draft

Up to year 2015

Up to year 2015, the policy of importing diesel with 2500 ppm or less sulfur content
may continue. Meanwhile, the diesel produced by ERL will continue to be blended
with the imported one to keep the sulfur content within the current 2500 ppm level.
During this period details of three policies should be finalized in parallel. These
include (i) Standardization of sulfur content measurement of diesel fuel
(ii) Up gradation of emission control regulations for diesel vehicles/engines
(iii) Implementation of preventative measures against fuel adulteration

Preparative measures shall be taken to import diesel with 500 ppm sulfur content from
the year 2016.

ERL should also plan and start its modernization process to provide diesel with lower
sulfur content.

Policy regulations for marketing of ERL diesel to restricted customers like diesel
power plants, railway and inland water transport can be included in this range.

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Final Draft

PROPOSED ROADMAP FOR SULFUR REDUCTION IN DIESEL FUEL

Timeline (Years)

Sulfur Content
(PPM)

2014

2015

2016*

2017

2018

2019**

2020

2021

2022**

2023

2024

2025*

[All over Bangladesh]

2500

2500

500

500

500

500

350

350

350

50

50

50

Standardization
of Sulfur Content
of Diesel

Regulation
regarding
Emission Control
in Vehicles

Control of Fuel
Adulteration

Monitoring of
Fuel
Adulteration

2500
or
less

2500
or
less

500
or
less

500
or
less

500
or
less

500
or
less

350
or
less

350
or
less

350
or
less

50
or
less

50
or
less

50 or
less

5000
or
less

5000
or
less

5000
or
less

5000
or
less

5000
or
less

5000
or
less

350
or
less

350
or
less

350
or
less

50
or
less

50
or
less

50 or
less

Awareness
Program for
using LSD
Imported Diesel
(PPM)

ERL Diesel
(PPM)
Blending of
Import and ERL
Diesel
Restricted
Marketing of ERL
Diesel

*revision recommended

**revision mandatory

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Final Draft

From the year 2016 till 2019

From the year 2016, import of diesel with 500 ppm or less sulfur content will only be
allowed. The imported fuel will go through the distribution network without blending.

ERL will start its renovation/expansion program for producing diesel with lower
sulfur content. At present, this is planned to take about three years, reaching a sulfur
content of 350 ppm.

Blending of diesel produced by ERL with the imported fuel will not be allowed
during this period. ERL will market its production of high sulfur diesel to restricted
customers only, which may include diesel run power plants, railway and inland
water vessels etc.

All the new diesel vehicles will be mandatory to satisfy the emission regulations,
which generally would require post-engine emission control devices like DPF and
DOC, catalytic converters, etc.

Old vehicles and engines will continue to operate using diesel with sulfur content of
500 ppm.

From the year 2020 till 2022

From the year 2020, import of diesel with 350 ppm or less sulfur content will only be
allowed. This is restricted due to the current plan of ERL to produce 350 ppm diesel.
In case the ERL diesel has lower ppm, the sulfur content of imported fuel can also be
reduced accordingly.

Since the sulfur content of both imported and ERL diesel are of the same order they
could be used separately or after blending.

ERL will continue to improve its process facilities in order to produce diesel with
sulfur content of 50 ppm or less.

For all new diesel vehicles it will be mandatory to satisfy the emission regulations,
which generally would require post-engine emission control devices like DPF,
catalytic converter, and DOC. The proportion of the newer vehicles and engines is
expected to increase significantly in the whole fleet.

From the year 2023 till 2025

From the year 2023, import of diesel with 50 ppm or less sulfur content will only be
allowed.

Since the sulfur content of both imported and ERL diesel will be of the same order,
they could be used separately or after blending.
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Final Draft

If we superimpose the proposed roadmap in the following figure from the Clean Air Asia
(CAA), "Current and Proposed Sulfur levels in Diesel in Asia, EU and USA", it can be
observed that most developed nations such as the EU, Japan and the USA, have already setup
and implemented a sulfur level of 10 to 15 ppm back in 2007-2008. Most other nations are
implementing a sulfur level of 50 ppm including our Asian neighbors, such as, India, China
and Sri Lanka. China and India setup a split standard for their metros (with lower ppm) and
other regions (with higher ppm). So, it can be concluded that reduction in sulfur is a necessity
for us to remain compatible with the global community. But the roadmap to that reduction
could be in line with our techno-economic feasibility. For example, right now a reduction of
sulfur level to 50 ppm or 10 ppm would be a very drastic measure for Bangladesh. Also the
split standards are not recommended for a small country like Bangladesh with small
jurisdiction, cross-country traffic movement and complicated administration.

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Final Draft

Proposed Roadmap of Bangladesh Presented with the Existing Roadmaps of Other Countries

[Source: CAI-Asia. 2010. Current and Proposed Sulfur levels in Diesel in Asia, EU and USA]
Notes: a - under consideration/ discussion; uncertain; b = nationwide supply of 50 ppm commenced in 2003 and for 10 ppm in 2005 due to voluntary goals set by the oil industry; c = marketed;
d = mandatory; e = voluntary standard of 500 ppm, however formal standard remains 2000 ppm, product in the market nationwide varies 500-1000 ppm; f = various fuel quality available;
g = Beijing, Guangdong, Shanghai

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Final Draft

10. MILESTONES FOR INTRODUCING LSD

The following are prominent milestones for the proposed roadmap to make it successful.
Table below shows the major stakeholders associated with milestone events in Bangladesh
with the suggested "Lead Organization" shown in Bold letters.
Table 4: Milestones for introducing LSD in Bangladesh
Event
Sequence

Milestones

Stakeholder / Agency
Associated

Recommended
Time Line for
Implementation

Finalization of roadmap for low

sulfur diesel

DoE

2014-15

2a

Standardization of sulfur content

measurement in diesel as per the
proposed roadmap

BSTI, ERL, BPC, DoE

2015

2b

Up-gradation of relevant
standards (Fuel, Vehicle
Emission)

BSTI, ERL, BPC, DoE

2015

2c

Up gradation of regulation of
emission from diesel vehicles

DoE, BRTA,
Ministry of Commerce,
Vehicle Importers/
Vehicle Assembles

2015

2d

Control of fuel adulteration

BPC, ERL, Home

Ministry, Police

2015

2015

3a

Economic analysis of using LSD

DoE, Ministry of Power,

Energy & Mineral
Resources, BPC,
Ministry of Finance
Ministry of
Communication, BRTA

3b

Arrangement of a pilot project to

run Bangladeshi vehicle fleet with
LSD

DoE, ERL, BRTA

2015

3c

Arrangements for import of diesel

with 500 ppm or less sulfur
content

Ministry of Power,
Energy & Mineral
Resources, BPC,
Ministry of Finance

2015

3d

Awareness program for the end

users regarding use of LSD

DoE, ERL, BRTA

2015-2022

ERL, Ministry of
Power, Energy &
Mineral Resources,
BPC, PDB, BR,
BIWTC, BIWTA, Local
Industry

2015

3e

Planning for restricted marketing

of ERL diesel from 2016

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Final Draft

Event
Sequence
4**

Milestones

Stakeholder / Agency
Associated

Recommended
Time Line for
Implementation

ERL up gradation / renovation for

producing sulfur content of diesel
to 350 ppm or less

ERL, Ministry of
Finance, BPC, Donor
Agencies

2015-2018

BPC, ERL, Home

Ministry, Police

2016-2025

Monitoring of fuel adulteration

control measures

6a

Import of diesel with 500 ppm or

less sulfur content

6b

Marketing of ERL diesel to

restricted customers

7a

Up-gradation of relevant
standards (Fuel, Vehicle
Emission)

Ministry of Power,
Energy & Mineral
Resources, BPC,
Ministry of Finance
ERL, Ministry of
Power, Energy &
Mineral Resources,
BPC, PDB, BR,
BIWTC, BIWTA, Local
Industry

2016

2016-2019

BSTI, ERL, BPC, DoE

2019

7b

Arrangements for import of diesel

with sulfur content of 350 ppm or
less

Ministry of Power,
Energy & Mineral
Resources, BPC,
Ministry of Finance

2019

7c

Production of diesel from ERL

with sulfur content of 350 ppm or
less

ERL, BPC

2019

7d

Review of Road map for 350 ppm

LSD

DoE, All Stakeholders

2019

Ministry of Power,
Energy & Mineral
Resources, BPC,
Ministry of Finance
ERL, Ministry of
Finance, BPC, Donor
Agencies

Import of diesel with 350 ppm or

less sulfur content

9**

ERL up gradation / renovation for

improving sulfur content of diesel
to 50 ppm or less

10a

Review of Road map for 50 ppm

LSD

DoE, All Stakeholders

2022

10b

Up-gradation of relevant
standards (Fuel, Vehicle
Emission)

BSTI, ERL, BPC, DoE

2022

10c

Arrangements for import of diesel

with sulfur content of 50 ppm or
less

Ministry of Power,
Energy & Mineral
Resources, BPC,
Ministry of Finance

2022

31

2020

2020-2022

Final Draft

Event
Sequence

Milestones

Stakeholder / Agency
Associated

Recommended
Time Line for
Implementation

10d

Production of diesel from ERL

with sulfur content of 50 ppm or
less

ERL, BPC

2022

11

Import of diesel with 50 ppm or

less sulfur content

Ministry of Power,
Energy & Mineral
Resources, BPC,
Ministry of Finance

2023

12

Review of Road map for LSD

with less than 50 ppm sulfur
content

DoE, All Stakeholders

2025

** currently the sulfur content is planned to be reduced to 350 ppm, in case it is reduced to
50 ppm event 4 and 9 can be blended together.
*** Lead Organizations shown in Bold letters

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11. CONCLUSIONS

All the stakeholders generally agreed that it is necessary to reduce the sulfur
content of diesel fuel. The consultant team (BUET) is of the opinion that
proposing drastic reduction in the sulfur content in diesel from the existing
2500 ppm down to 50 ppm seems unrealistic given the socio-economic,
technological and political situations in Bangladesh. So it suggests a rather
pragmatic approach of going down the road in phases as it seems more
feasible for implementation.

Since more than 85% of HSD consumed in Bangladesh at present is imported

as the final product, BPC can start importing diesel with lower sulfur content.
However, 15% diesel comes as one of the products from processing crude oil
by ERL. Being a refinery established decades ago, ERL produces diesel with
higher sulfur content, but the associated products like HSFO, octane,
kerosene and petro-chemicals are essential fuels and raw materials for other
sectors. Currently, ERL diesel is being blended with imported one resulting in
a sulfur content of 2500 ppm which is the existing standard in Bangladesh.

Based on the socio-economic condition of Bangladesh as well as the global

and regional trends a roadmap for use of LSD in Bangladesh has been
proposed. Input and feedbacks from a wide range of stakeholders have been
sorted in a number of occasions, through seminars, focus group discussions,
field-visits and data collection.

The approach of gradual change from a HSD to LSD is considered to be more

pragmatic and realistically achievable in the socio-economic context of
Bangladesh. The road to use LSD is divided in three successive phases after
preliminary preparation work. This preparation phase in 2015 must include
activities involving - standardization of measurement procedure for sulfur
content in diesel fuel, up-gradation of emission control regulations for diesel
vehicles / engines, and introduction of prevention control measures against
fuel adulteration. Implementation of these three milestones is essential for
getting the real benefit of using LSD fuel for a better environment.
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Final Draft

Reduction of sulfur content to 500 ppm is proposed from 2016. After the
proposed renovation of ERL facilities this is suggested to be reduced to 350
ppm from 2020. From 2023, the whole system should be ready for using LSD
of 50 ppm. Important milestones with concerned timelines have been detailed
in the proposed roadmap. Intermediate review of the proposed roadmap is
essential which is proposed in 2019 and 2022. This would allow to
accommodate changes in national or global scenario along the timeline of the
roadmap.

The activities associated with the roadmap involve a wide range of

government and private bodies. A good co-ordination between associated
agencies will be essential. Keeping all such relevant stakeholders onboard is
essential for successful implementation of the proposed roadmap.

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Final Draft

12. FUTURE PLANS

The consultant team (BUET) proposes the roadmap up to the year 2025 including
recommendations for the revisions of the roadmap at a convenient time interval of
three/four years. However, in 2019 and then in 2022, the roadmap must be revised to
adapt to the then prevailing socio-economic, environmental, technological, political
and health situations of the country as well as the global trends.

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APPENDIX-A
(SUMMARY OF MEETINGS WITH FOCUS GROUPS AND STAKEHOLDERS)

Total six meetings were conducted from May 2013 to February 2014 at Dhaka and
Chittagong with all the stakeholders and some specific focus groups. The Focus Groups (FG)
consists of department of environment, vehicle business groups, government enforcement
authorities, Oil companies, Oil distributors and Oil refinery. In different meetings,
representatives from different organizations were present and the consultant representative
(BUET) initiated the discussion with a long time multimedia presentation. The participants
were given some specific questions relevant to their business / duties / research etc., the
discussions were most of the time continued on the basis of the questions and their
corresponding answers. In this appendix, the highlighted portion of the conducted meetings is
summarized.

The first meeting was held on May-28, 2013 at the Department of Environment (DoE),
Agargoan, Dhaka. The welcome speech mentioning the objectives of the meeting was
delivered by the Director (Planning), DoE, GOB. A presentation titled Fuel and Vehicle
Emission Standards: Trends in Asia, was delivered by a representative from Clean Air Asia
(CAA). She presented the current activities of CAA, goals for Asia up to 2016 regarding
Better Air Quality (BAQ). A technical consultant (from Dept. of Mechanical Engineering,
BUET) of this road map project, presented "Reducing Black Carbon from Heavy Diesel
Vehicles and Engines". He explained the emission formation mechanism from high sulfur
diesel engines and its remedy. He also asked for the co-operation from all the stake holders
for proposing a road map to get a diesel pollution free environment. Director General, DOE
and the Chair in his closing speech emphasized the need for clean air in Bangladesh. He said
that we need a simultaneous approach to improve fuel quality, control of vehicular emission
and introduce an efficient traffic management system.

The second meeting was held on July 29, 2013 at the Department of Environment (DOE),
Agargoan, Dhaka. The welcome speech mentioning the objectives of the meeting was
delivered by Director (Planning), DOE, GOB. He gave a brief account of DOEs involvement
on efforts taken towards lower emission and cleaner fuels. Participants and experts from
different relevant organizations (BRTA, DOE, representatives from Bus Owner Association,
representative from vehicle importers) were present on the occasion. Presentations were made
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Final Draft

by some of the experts, followed by comprehensive discussions and finally a number of

recommendations were put forward by all the participants.
The first presentation titled Reducing Black Carbon from Heavy Vehicles & Engines in
Bangladesh was delivered by Deputy Director (Engg.), Bangladesh Road Transport
Authority (BRTA), Dhaka. He started his presentation with a brief introduction of BRTA. He
presented the statistics of type-wise registration of vehicles up to 2009 and vehicles registered
in 2010, 2011 and 2012 in Bangladesh. According to the statistics of BRTA the total number
of registered vehicle in Bangladesh up to 2012 was 18,44,335. The number of registered
vehicle in Dhaka city up to 2012 was 7,25,597. He mentioned that vehicular emission is one
of major sources of air pollution in Bangladesh.

Technical consultant from the Department of Mechanical Engineering, Bangladesh

University of Engineering and Technology (BUET) presented Diesel Engine Emission
Technical Aspects. At first he presented the basic mechanism, characteristics and
applications of diesel engines. The combustion mechanism inside the engine cylinder and
pollution formation was explained in his presentation. He also presented the effect of
pollutants on health, environment and on engine itself. He presented and discussed the
existing technology for controlling the pollution from diesel engines. During his presentation
he emphasized on the quality of fuel for diesel engines and emissions from diesel engines. He
also discussed about the recent trends in diesel fuel in other countries. He focused on the
advantages and disadvantages of Low Sulfur Diesel (LSD) and Ultra-low Sulfur diesel
(ULSD). He informed the meeting that diesel containing high sulfur develops corrosion in the
cylinder, piston, piston rings and exhaust system. The emissions from diesel engines make
the emission control devices (like catalytic converter, DPF, etc) inactive when the engine
runs with high sulfur diesel. He also mentioned that low sulfur content in diesel reduces the
lubricity of diesel, which can be recovered by using some additive at some cost. His
conclusion was that the benefits of low sulfur fuels are much greater than the costs. Finally,
he suggested to take immediate action for the preparation of a road map and its
implementation for Low Sulfur Diesel (LSD) in Bangladesh.

A representative from vehicle importers informed that they import brand new diesel vehicles
which are designed for LSD and equipped with emission control devices (like catalytic

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Final Draft

converter, DPF, etc.) but due to unavailability of LSD they have to remove the emission
control devices from the vehicles.

Finally, the chairman summarized the presentations and emphasized for an emission free
Bangladesh. He focused on simultaneous approach among- fuel quality, vehicle emission,
traffic system and co-ordination between the relevant authorities. He thanked all the
participants and declared the meeting closed.

The first focus group meeting was held on August 04, 2013 in Chittagong with Bangladesh
Petroleum Corporation (BPC) and Eastern Refinery Limited (ERL) and all other oil
distribution companies of the Bangladesh. At the beginning Director (Planning), DoE, GOB
gave a brief description of the objectives of the project. Director (Marketing) of Bangladesh
Petroleum Corporation (BPC) presided over the meeting. There are about total thirty
participants from different disciplines of the above mentioned institution participated in the
group discussion. The technical consultants of the project from (BUET) informed the
participants about the advantages of using low sulfur diesel in engines and vehicles. The
consultation team also requested to BPC and ERL to provide some statistical data /
documents which will be helpful for preparing the road map of the present project. After a
two hours fruitful discussion, the chairman of the session assured the participants that BPC
will do its best to implement the project and to have a pollution free environment. He then
declared the closing of the discussion session.

After the focus group meeting, the consultation team members of BUET along with Director
(Planning), DOE, GOB participated in a field visit to ERL, Chittagong. DGM (planning and
shipping), ERL assisted the team to understand different process of ERL. The team also
visited the testing laboratory of ERL. The team members similarly requested to provide some
statistical data / documents of ERL for assisting the preparation of road map which is the key
objective of the project. Finally, BPC and ERL provided some useful data and the answers of
the questionnaires' which were distributed in the meeting.

The second focus group meeting was held on October 23, 2013 at Department of
Environment (DOE), Agargaon, Dhaka with presence of Diesel Vehicles Importers'
Association of Bangladesh and Bus-Truck Owners' Association of Bangladesh. The meeting
was usually began with a welcome speech delivered by Director (Planning), DOE, GOB
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mentioning the objectives of the meeting. Technical consultant from the Department of
Mechanical Engineering, Bangladesh University of Engineering and Technology (BUET)
provided a multimedia presentation. The consultant discussed very briefly the various
technical aspects of diesel engines and diesel vehicles with particular emphasis on diesel
emissions and their severe detrimental effects on environment and eventually to human
health. He also showed several emission control mechanism that can be employed in diesel
engines and diesel vehicles to reduce emissions. He put major emphasis on the quality control
of diesel fuel especially by reducing its sulfur content.

Representative from vehicle importers informed the meeting that Euro II/III vehicles cannot
be run without fuel correction. Also fuel statistics are required for newer vehicles import.
Another participant also informed that vehicles will not be available for running below Euro
IV standard after March, 2015. Regarding import from China, it was informed that Chinese
govt. is imposing severe restrictions on producing engines/batteries that cause environmental
pollution. So no conventional engines will be available after around March, 2015. Some
participants commented that the protection against the adulteration of lubricating oil and
diesel fuel is absolutely essential. Lub. oil adulteration is very dangerous for the lifespan of
the engines and/or vehicles. Finally, Director (Planning), DOE, again reiterated the need for
Clean air in Bangladesh by controlling the fuel quality with cooperation from all relevant
sectors. He thanked all the participants and closed the meeting.
The third Focus Group Consultation Meeting of Reducing Black Carbon from Heavy Duty
Diesel Vehicles and Engines was held on 15 January 2014 at the Department of
Environment, Agargaon, Dhaka. The particapants of the meeting were mainly from the
enforcement authorities of environment of Bangladesh, like BRTA, Traffic Police, DOE,
BSTI. The Director General, Department of Environment presided over the meeting. The
welcome speech was delivered by Director (Planning), DOE and PD, Reducing Black Carbon
from Heavy Duty Vehicles and Fuels. He mentioned that a limit of ppm of sulfur in diesel
fuel has already been emposed by the Government of Bangladesh before, the ongoing road
map project hope to propose a new diesel fuel standard to be implimented within certain
years.

The technical consultants of the project from BUET an outline of updating the roadmap for
clean fuels for vehicles and stricter emission standards for Heavy Diesel Vehicle (HDV) and
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Light Diesel Vehicle (LDV) in Bangladesh. He explained the advantages and disadvantages
of using high sulfur diesel (HSD) and low sulfur diesel (LSD). He highlighted his discussion
for the use of high sulfur content diesel, which is very much harmful for the environment.
The pollutants produced from the combustion of high sulfur content diesel is carsinogenic
that might cause cancer. This pollutents can also make the emission control devices of
engines invalid. He also mentioned the disadvantges of using low sulfur diesel like decrease
of the fuel lubricity, increase of the chance for the formation of organic compound in fuel.

The representatives from different enforcement authorities participated in a discussion

session. The representative from the traffic polic mentioned that though LSD is costly, it
should be used because life is more valuable than anything. The representative from BSTI
mentioned that they need to increase their capability to maintain / monitor the new standard
for diesel fuel which will be proposed in the coming road map. The DOEs representative
highlighted that the sulfur ppm in diesel vary from the supply source (Eastern Refinery
Limited) to petrol pump i.e. there can be a survey if there is any adulteration during
transportation / distribution of fuel.

Finally, Chairman of this discussion meeting, delivered his concluding remarks and declared
the meeting close. He promised to do everything for a pollution free environment.
The fourth Focus Group Consultation Meeting of Reducing Black Carbon from Heavy Duty
Diesel Vehicles and Engines was held on 25 February 2014 at the Department of
Environment, Agargaon, Dhaka. The participants of the meeting were mainly from the
Diesel-Petrol Pump Owners Association, Generator Importers and Private Sector Power Plant
Companies. The Director General, Department of Environment presided over the meeting.
The welcome speech was delivered by the Director (Planning), DOE and PD of Reducing
Black Carbon from Heavy Duty Vehicles and Fuels. He mentioned that DoE has invited all
major stakeholders of this environmental issue in a series of Focus Group Discussion
(FGD) meetings to get their respective views. Only with involvement and coordination
among the stakeholders an effective roadmap can be proposed.

The representative from BUET, as a technical consultant of this road map project, presented
an outline for Reducing Black Carbon from Heavy Duty Vehicles and Fuels. He explained
health effect of diesel pollution and the objectives of using low sulfur content diesel.
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Different ways of reducing air pollution due to combustion of diesel and effect of sulfur
content of fuel on them was highlighted. He also mentioned the advantages and
disadvantages of using low sulfur diesel (LSD). Finally, he concluded that we should go for
LSD to cope with the rest of the world

The representative from petrol pump owners association boldly delivered his long practical
experience in the meeting. He mainly talked about the adulteration of fuel (including diesel)
in different stages of handling from port up to the end user (i.e. the vehicle users). He believe
that there is wide spread adulteration of fuels and finally, he recommended that all the
concern authorities should be under accountability. He emphasized that without proper
control of adulteration at field level all the efforts for reducing pollution by improvement of
fuel quality may prove to be fruitless.

The representative from diesel generator power plants informed the meeting that the
generating capacity of liquid-fuel run power plant in and around Dhaka city is about 300 MW
and near future it may meet 1000 MW. They are using heavy fuel oil (HFO) of certain type
that meet the specified requirement of fuel set by the engines' manufacturers. Generally the
sulfur content of HFO is pretty high, but there was no reliable measurement record so far. In
some cases the foreign donors ask for emission requirement but de-sulfurizing units are still
very uncommon. The representative from generator importer association informed the
meeting that still they have no restriction of sulfur content in fuel for running their engines
used to run the generator for producing electricity. He also informed that in future they might
undergo the sulfur content restriction for their usable fuels.

One representative from vehicle importer association was present in the meeting. He briefed
that for recent models of vehicles, their fuel quality requirement could not be met by the
available fuel in the market in Bangladesh. Some important parts like fuel pumps, injectors
and emission control devices become out of order due to low quality fuels. He also informed
that the latest and high efficient vehicles have high demand but the available fuels in
Bangladesh do not permit to import those vehicles. Modern diesel emission control devices
like DPF, DOC or SCR are rarely used in vehicles imported in Bangladesh, although there
are vehicular emission rules implemented from 2006.

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At the end of the discussion, Chairman of the meeting, delivered his concluding remarks and
declared the meeting close. He requested everybody to work together in a coordinated way
for a pollution free environment.
The discussion Meeting of Reducing Black Carbon from Heavy Duty Diesel Vehicles and
Engines at its mid-term stage was held on 09 April 2014 at the Department of Environment,
Agargaon, Dhaka. The participants of the meeting were mainly from the representative from
DoE, Clean Air Asia (CAA), Vehicle Importer Association, Communication Ministry, BSTI,
Ministry of Energy and Mineral Resouces, Science Laboratory and Bus-Truck Owner
Association. Mr. Md. Raisul Alam Mondal, Director General, Department of Environment
presided over the meeting. The welcome speech was delivered by Mr. Quazi Sarwar Imtiaz
Hashmi, Director (Planning), DOE and PD of Reducing Black Carbon from Heavy Duty
Vehicles and Fuels. He mentioned about the objectives of the present meeting. The time line
roadmap for sulfur (ppm) reduction in diesel and the recommendation regarding
improvement of Eastern Refinery Limited (ERL) were the main discussion topic.

Dr. Nurul Quadir, Joint Secretary (Environment) and Focal Point, Reducing Black Carbon
from Heavy Vehicles and Fuels discussed about the participation of Bangladesh for reducing
world environmental pollution. Mr. Md. Yunus Ali, Chief Conservator of Forests,
Bangladesh Forest Department delivered his speech highlighting that a combined initiative by
different authorities like BRTA, ERL, Commerce Ministry, Vehicle Importers, Fuel
Distributors can create a pollution-free Bangladesh. Mr. Rafiqul Islam, Chief Guest and
Additional Secretary (Environment), Ministry of Environment and Forests delivered his
speech mentioning that with the cooperation from all, the present initiative can certainly
produce a fruitful roadmap for reducing the black carbon. He mentioned is our constitutional
duty to create a pollution free environment.

Prof. Dr. Maglub Al Nur, Department of Mechnaical Engineering, BUET, technical

consultant of this road map project, presented the draft roadmap to the forum for discussions
and recommendations. He highlighted the disadvantages of using high sulfur content diesel.
He mentioned that in two ways pollution can be controlled; one is by using post ignition
devices (like catalytic converter, DPM etc.) and the other is by using good quality fuels. He
presented sulfur level in diesel in different countries. He also informed the production,
import, consumption and sales data of HSD and HFO by ERL and BPC. He mentioned the
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blending statistics of ERL and their new proposal for plant development. He presented some
observations and findings related to HSD and its production, emission and adulteration.
Finally, he presented the draft proposal for the roadmap for Reducing Black Carbon from
Heavy Duty Diesel Vehicles and Engines in Bangladesh. He presented two options for the
sulfur content (ppm) reduction and timeline for the roadmap in the proposed draft and invite
the participants for the open discussion. Representative from Vehicle Importers informed the
participants that at the moment the major vehicle manufacturers are producing vehicles
compatible for only high quality (low sulfur) fuel and due to low quality fuel in Bangladesh
their sales volume is decreasing. He shared his experience of testing fuel samples at foreign
laboratories collected from Dhaka showing high level of sulfur.

A representative from communication ministry informed that due to use of Low Sulfur Diesel
(LSD), the cost for transportation will be increased and therefore all the relevant departments
of communication ministry should invite in future meeting. The increase of price should also
ensure the low sulfur content of the fuel. Representative from BSTI informed the forum that
ERL needs desulfurization plant for producing LSD. Representative from Energy Ministry
informed that the cost of diesel per liter will increase if LSD is imported. To do so,
government needs more subsidy or have to solve the problem for increasing transportation
cost. Therefore, a rigorous economic analysis has to be performed to propose the roadmap.
One representative from Science Laboratory mentioned that BSTI should be more active to
get a standard that is necessary for pollution free environment.

Two representatives from Clean Air Asia (CAA) were present in the meeting. They were
informed about the proposed road map and contents of discussion. Mr. Md. Raisul Alam
Mondal, Chairman of this discussion meeting, delivered his concluding remarks and declared
the meeting close. He expressed his opinion that to get a healthy environment, we have to
maintain standard of fuel quality up to the end users.
The Fifth Focus Group discussion Meeting of Reducing Black Carbon from Heavy Duty
Diesel Vehicles and Engines was held on 25 June 2014 at the Department of Environment,
Agargaon, Dhaka. The participants of the meeting were mainly from the representatives of
DoE, BADC, BSTI, BRTC, ERL, Communication Ministry, Ministry of Energy and Mineral
Resouces.

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Mr. Md. Shahjahan, Additional Director General, Department of Environment presided over
the meeting. The welcome speech was delivered by Mr. Quazi Sarwar Imtiaz Hashmi,
Director (Planning), DOE and PD of Reducing Black Carbon from Heavy Duty Vehicles
and Fuels. He mentioned that among the most polluted cities in the world, Bangladesh
belongs to top few of them. He requested all the participants to finalize the road map for
making a pollution free Bangladesh.

Prof. Dr. Md. Mamun, Department of Mechnaical Engineering, BUET and technical
consultant of this road map project, presented the roadmap (draft) to the forum for
discussions, recommendations and suggestions for getting it implemented. He discussed the
disadvantages of using high sulfur content diesel. He presented sulfur level in diesel in
different countries. He mentioned the blending statistics of ERL and their new proposal for
plant development. Finally, he presented the draft proposal for the roadmap for Reducing
Black Carbon from Heavy Duty Diesel Vehicles and Engines in Bangladesh. He described
two options for the timeline of the roadmap in the proposed draft and invited the participants
for the open discussion.

Representative from Department of Electricity proposed that the blending by ERL for diesel
should be stopped soon; Prof. Ehsan explained that ERL processes crude oil not only for
producing diesel, a number of other fuels like Petrol/Octane, Kerosene, Jet fuels as well as
raw materials for a number of petro-chemical industries are also produced in this process.
Hence it is not practical to stop blending unless a separate market for the diesel produced by
ERL is found and this process may need some time. It was stated that there may be possibility
of using ERL diesel in a section of the power generation facilities, but the feasibility needs to
be explored.

Representative from BSTI mentioned that they have some meetings for making a standard of
using 500 ppm sulfur from June, 2016. The forum expressed their opinion that there should
be coordination among all the stake holders. One representative from Energy Ministry
mentioned that the government has decided to import LSD and advised to start using.
Representative from communication ministry expressed his opinion that every stake holders
must be included in the roadmap project and the financial implication on the economy needs
to be investigated to more details.

The representatives from BIWTC and BRTC were

concern about the increase of transportation cost due to use of LSD instead of HSD. The
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representative from Bangladesh Railway informed that they only use about 32,000 tons of
diesel per year which is a very small part (about 1%) of the total demand. The yearly use of
diesel by BIWTC is only about 13,000 tons, however the private sector is the bigger user in
this field.

Mr. Md. Shahjahan, Additional Director General, Department of Environment, Chairman of

this discussion meeting, delivered his concluding remarks and declared the meeting close. He
expressed his opinion that this roadmap is related to public health and for this reason we are
trying to develop this map with the concern of all the relevant sectors. He also emphasized
that complications in one or two sectors cannot be given priority over the greater goal of
better health to citizens and improving the environment.
The 2nd National Stakeholder Consultation Meeting of Reducing Black Carbon from Heavy
Duty Diesel Vehicles and Engines was held on 29 October 2014 at Bidhut Bhaban,
Bangladesh Power Development Board, Dhaka. The participants of the meeting were mainly
from the representatives of DoE, BADC, BSTI, ERL, Ministry of Energy and Mineral
Resources, Truck owners' Association and Petrol Pump Owners' Association.

Mr. Md. Raisul Alam Mandal, Director General, Department of Environment presided over
the meeting. The welcome speech was delivered by Mr. Quazi Sarwar Imtiaz Hashmi,
Director (Planning), DOE and PD of Reducing Black Carbon from Heavy Duty Vehicles
and Fuels. He mentioned that we have to reduce sulfur in diesel to a minimum level
gradually considering our socio-economic condition. He requested all the participants to
finalize the road map for making a pollution free Bangladesh.

Prof. Dr. Md. Ehsan, Department of Mechanical Engineering, BUET and technical consultant
of this road map project, presented the proposed roadmap to the forum for discussions,
recommendations and suggestions for getting it implemented. He briefly discussed the
disadvantages of using high sulfur content diesel. He presented sulfur level in diesel in
different countries. He mentioned the blending statistics of ERL and their new proposal for
plant development. Finally, he presented the proposed roadmap for Reducing Black Carbon
from Heavy Duty Diesel Vehicles and Engines in Bangladesh. He described the timeline of
the roadmap and the plan of action to execute the roadmap and invited the participants for the
open discussion.
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Mr. Md. Shahjahan, Additional Director General, Department of Environment, was the
facilitator of the discussion meeting. He invited the participants for making constructive
comments on the roadmap. Representative from BAPA (Bangladesh Poribesh Andolon)
suggested to reduce the use of sulfur in Bangladesh. He also advised to consider the traffic
congestion during the consideration of environmental pollution. The representative from DoE
suggested that the more details of technical, economical and political involment have to be
included in the proposed roadmap. He also mentioned that there should have initiative to
advertise among the users that the use of low sulfur diesel (LSD) will not harmful for the
present fleet of the country which are now run by high sulfur diesel (HSD). Representative
from Bangladesh Agriculture Development Corporation advised that there might have
practical survey for a short period of time by using LSD with the present fleet to verify
whether the use of LSD harmful or not for the present fleet. Representative from Petrol Pump
Owners' Association mentioned that we should not wait for a long time to import LSD, it
should be done immediately. He also suggested to stop adulteration and to ensure low sulfur
ppm in diesel.

Mr. Md. Raisul Alam Mandal, Director General, Department of Environment, Chairman of
this discussion meeting, delivered his concluding remarks and declared the meeting close. He
expressed his opinion that everybody should take this roadmap positively. He requested all
the stakeholders to save our environment and public health. Mr. Quazi Sarwar Imtiaz
Hashmi, Director (Planning), DOE and PD of Reducing Black Carbon from Heavy Duty
Vehicles and Fuels acknowledged everybody to attend the discussion meeting for making a
fruitful roadmap.

The National Stakeholder Consultation Meeting for Proposed Final Draft (3rd Draft of
Roadmap) of Reducing Black Carbon from Heavy Duty Diesel Vehicles and Engines was
held on 14 January 2015 at Department of Forest, Dhaka. The participants of the meeting
were mainly from the representatives of DoE, Clean Air Asia, BRTA, BSTI, BPC, ERL,
Ministry of Energy and Mineral Resources, Ministry of Industries, Bangladesh Railway,
BCSIR , Vehicle Importers' Association.

Mr. Md. Raisul Alam Mandal, Director General, Department of Environment presided over
the meeting. The welcome speech was delivered by Mr. Quazi Sarwar Imtiaz Hashmi,
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Director (Planning), DOE and PD of Reducing Black Carbon from Heavy Duty Vehicles
and Fuels. He requested all the participants to finalize the road map so that we can create a
pollution free Bangladesh.

Mr. Parthaa Bosu, India Director and South Asia Liaison, Clean Air Asia explained the
involment of Clean Air Asia (CAA) in different cities, in different regions and in different
countries. He briefly described the sectors of environment the CAA is now working. He
expected a fruitful roadmap for Bangladesh to make it pollution free.

Prof. Dr. Md. Ehsan, Department of Mechanical Engineering, BUET and technical consultant
of this road map project, presented the proposed final draft roadmap to the forum for
providing the last stage suggestions for getting it implemented. He briefly discussed the
disadvantages of using High Sulfur Diesel (HSD) and advantages of using Low Sulfur Diesel
(LSD). Finally, he presented the proposed final roadmap for Reducing Black Carbon from
Heavy Duty Diesel Vehicles and Engines in Bangladesh. This roadmap incorporated
milestones of lowering the standard sulfur content on imported diesel fuel from the current
level of 2500ppm to a stricter level of 500ppm by 2016. Eventually, it is targeted to be as low
as 350ppm by 2020 and 50ppm by 2023. The consultation team recognizes the technical,
economic and socio-political implications of pursuing stricter standards. They suggested that
proper co-ordination of activities like - standardization of measurement of sulfur content in
diesel, up gradation of vehicle emission standard for low sulfur diesel and effective control of
fuel adulteration is essential to achieve the full benefit of using low sulfur diesel. The process
should be accompanied by a public awareness program to create a better understanding
regarding the use of low sulfur diesel among the end users. The consultation team also
suggested a strategy for Eastern Refinery Ltd (ERL), the only major local producer of fuel in
the country, to be able to cope up with such reduction on sulfur level.

Mr. Md. Mosharraf Hossain Bhuiyan, Secretary, Ministry of Industry was present in the
meeting as a Chief Guest. He expressed his opinion that the proposed roadmap is realistic and
he assured that BSTI will do their best to make the roadmap to be a standard.

After an extensive presentation by the consultant and speech delivered by the resource
persons, an open discussion was conducted among the stakeholders. Representative from
BADC showed his concern regarding the increase of cost of LSD which will be directly
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related to the cost in agricultural sector. In this regard, Prof. Ehsan suggested to conduct an
economic analysis on the impact of increase of diesel price in all sectors who are using diesel
directly or indirectly. A representative from Bangladesh Railway wanted to know the use of
LSD in old model engines used by railway. Prof. Ehsan replied that LSD can be used in old
engines, but an investigation should be made to run old engines with LSD whether there is
any negative effect on the old engines or not. Representative from oil distribution company
said that the restricted use and distribution of HSD will be a difficult job due to the chances
of mixing of LSD and HSD during transportation and distribution. The forum replied to face
that difficulty as it is a national issue. The representative from ERL expressed his
encouraging opinion regarding the roadmap. They expected all sectors co-ordination to
execute the roadmap. The representative from Ministry of Industry suggested that there
should have the direction for the sustainability of the roadmap. The representative from DoE
suggested to include the Ministry of Commerce as a stakeholder in this roadmap. The
representative from BRTA expressed his opinion that they will do everything what is
necessary for the environment and they will follow DoE. The forum expected that in the
roadmap there should have a suggestion for a body who will play a leadership role for all
kind of co-ordination during the execution of the roadmap.

The representative from Ministry of Energy and Mineral Resources informed the meeting that
they will start importing 500ppm diesel within the year 2015. The forum took it very
positively for the execution of the roadmap.

Mr. Quazi Sarwar Imtiaz Hashmi, Director (Planning), DOE acknowledged everybody to
attend the discussion meeting for making a fruitful roadmap and declared the meeting close.
He requested all the stakeholders so that the present initiation should not be demolished in
this discussion table.

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APPENDIX-B
FIRST DRAFT OF THE PROPOSED ROAD MAP
Finally the first draft roadmap for developing low sulfur fuel and clean vehicle emissions
policies in Bangladesh is framed as follows:

Option-1:
Timeline (Years)

Sulfur Content
(PPM)

2014

2015

2016*

2017

2018**

2019

2020*

2021

2022

2023**

2024

2025

[All over Bangladesh]

2500

1500

1500

500

*
500

500

500

350

350

350

50

50

Standardisation
of Sulfur Content
of Diesel
Regulation
regarding
Emission Control
in Vehicles
Control of Fuel
Adulteration

Option-2:

Sulfur Content
(PPM)
[All over Bangladesh]

Standardisation
of Sulfur Content
of Diesel
Regulation
regarding
Emission Control
in Vehicles
Control of Fuel
Adulteration

Timeline (Years)
2014

2015

2016*

2017

2018**

2019

2020*

2021

2022

2023**

2024

2025

2500

2500

500

500

*
500

500

500

350

350

350

50

50

*revision recommended
**revision mandatory
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1. Reduction of the sulfur content in diesel from the existing 2500 ppm down to 50 ppm
at single stage seems unrealistic given the socio-economic and technological situation
in Bangladesh. So a rather realistic approach has been proposed for reducing sulfur
gradually, as it seems feasible from both the socio-economic and technological points
of view.
2. In the first draft, two options for the reduction in sulfur content in diesel were
preliminarily proposed for consideration as a part of this roadmap. Based on the
feedbacks from the stakeholders meeting, a suitable option was planned be finalized.
OPTION-1: An immediate reduction of sulfur content in diesel was proposed from
current level of 2500 ppm to 1500 ppm in 2015. This is based on the information that,
from 2015, a new fleet of vehicles requiring low sulfur diesel for their operation will
start entering the roads. However, most of the vehicle fleet still will be of the older
generations. So to reach a balance between the two generations of the diesel vehicles
and to minimize burden of higher fuel cost on the overall economy, an interim twoyear recess/breathing period with minimum reduction in sulfur content down to 1500
ppm was proposed. 1500 ppm is achievable by using the existing blending technique
using the ERL produced diesel as well (by blending it with imported 500 ppm diesel).
In the meantime, three parallel processes of
(i) Standardization of Sulfur Content in Diesel
(ii) Regulation of Emission Control from Vehicles and
(iii) Control Measures of Fuel Adulteration
need to be implemented within 2016. This will allow ERL more time to plan its
integration in the low sulfur market.
A further reduction from 1500 ppm to 500 ppm was proposed from 2017. By then,
many of the new generation vehicles demanding low sulfur diesel will be running on
the city streets. They will constitute a significant part of the total number of vehicles.
Further, to cope with the global supply/demand scenerio of both the fuel availability
and the engine manufacturing, a reduction to 500 ppm needs to be mandatory.
OPTION-2: A reduction in sulfur content in diesel was proposed from current 2500
ppm to 500 ppm in 2016. Till then, the current practice of 2500 ppm sulfur diesel will
be continued. In the meantime, three parallel processes of 50

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(i) Standardization of Sulfur Content in Diesel

(ii) Regulation of Emission Control from Vehicles and
(iii) Control Measure of Fuel Adulteration
need to be implemented. From 2016, the imported (500 ppm) fuel will no longer be
blended with high sulfur diesel produced by ERL. The ERL fuel needs to be marketed
separately to restricted clients such as power plants in remote areas, marine transports,
etc. After renovation of ERL, once the fuel quality is upgraded to the international
standard, only then it can be used for the road transport sector. To cope with the
global supply/demand scenario of both the fuel availability and the engine
manufacturing, a reduction to 500 ppm needs to be mandatory.
3. In the next phase, a reduction from 500 ppm to 350 ppm in 2021 has been proposed.
This is again done to minimize the socio-economic and technological impulses.
4. Finally, in 2024, the eventual reduction of sulfur content to 50 ppm is proposed. Since
by then, almost all of the diesel vehicle fleet currently running on high sulfur content
diesel will be phased out, the vehicles demanding low-sulfur diesel (from 2015
onwards) will constitute the bulk share of the total vehicles and the vehicles from
newer generations demanding ultra-low sulfur diesel will be plying on the road.

5. Although the roadmap is shown up to 2025, but at every two/three years time interval,
the revision of the roadmap is recommended. And, after five years, the revision is
mandatory to accommodate the then prevailing socio-economic, technological and
global situations.

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6. If we superimpose our roadmap in the following figure from the Clean Air Asia (CAA),
"Current and Proposed Sulfur levels in Diesel in Asia, EU and USA", we observe that most
developed nations such as the EU, Japan and the USA, have already setup and implemented
a sulfur level of 10 ppm back in 2007-2008. Most other nations are implementing a sulfur
level of 50 ppm including our Asian neighbors, such as, India, China and Sri Lanka. China
and India setup a split standard for their metros (with lower ppm) and other regions (with
higher ppm). So, it can be concluded that reduction in sulfur is a must for us to remain
compatible with the global community. But the roadmap to that reduction could be in line
with our techno-economic feasibility. For example, right now a reduction of sulfur level to
50 ppm or 10 ppm would be a very drastic measure. Also the split standards are not
recommended for a small country like Bangladesh with small jurisdiction, cross-country
traffic movement and complicated administration.

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APPENDIX-C
(DOCUMENTS PROVIDED BY STAKEHOLDERS)

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