Equal Opportunity Sought for Light-Duty NGVs Under U.S. Rules

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Natural Gas Vehicles for America (NGVAmerica), supported by industry trade bodies and separately lodged member statements, have submitted comments to the National Highway Traffic Safety Administration (NHTSA) and U.S. Environmental Protection Agency (EPA) related to their proposed Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule for Model Years 2021-2026 Passenger Cars and Light Trucks.

In their submission, NGVAmerica, the Coalition for Renewable Natural Gas (RNG Coalition), the American Gas Association (AGA) and the American Public Gas Association (APGA) called upon NHTSA and EPA to use this rulemaking opportunity to expand incentives for NGVs in the light-duty sector—particularly for pickup trucks, work vans, and sport utility vehicles—highlighting several key benefits of natural gas use in transportation:

NGVs offer unmatched emission reduction benefits. Natural gas engines achieve emission reductions that are 90 percent cleaner than federal standards without requiring complex emission control systems or the use of additives. When fueled with renewable natural gas natural gas engines are carbon neutral—even carbon negative—reducing greenhouse gas emissions by upwards of 125 percent.
NGVs are road-tested, proven, and commercially-available today. No other powertrain is as sustainable, clean, domestic, abundant, safe, reliable, affordable, adaptable, and competitive across all vehicle classes.
NGVs save money and support American workers. Reliant on American technology, natural gas is a low cost, domestically-abundant fuel with an established and growing refueling infrastructure across the country. Economic benefits for light-duty NGV fleets are tremendous.
NGVs achieve real environmental and climate benefits without sacrificing passenger safety.

Written comments have also been filed by VNG.co LLC and Ariel Corporation who outlined a pathway for the agencies to maximize the nation’s emissions and petroleum conservation objectives with natural gas vehicles (NGVs).

VNG and Ariel state that, as acknowledged by the agencies, consumer preferences have shifted materially and differently than anticipated at the time of the 2012 rulemaking. The popularity of light trucks has grown unabatedly with consumers, and the popularity and impact of electric vehicles (EVs) continues to remain uncertain, particularly in the light truck segment given the utility and weight of these vehicles. As a result, progress for reducing emissions and improving fuel economy is jeopardized under the current regulations.

This new rulemaking, along with current market dynamics—growing demand for light trucks, a significant increase in the availability of low-cost domestic natural gas, and the expanded availability of renewable natural gas—provides the right circumstances for the light-duty natural gas vehicle market to expand.

VNG and Ariel concur, urging the agencies to use the current rulemaking to provide automakers with strong regulatory incentives for producing NGVs on par with those provided in the 2012 rulemaking for the production of EVs.

Plea for Equal Opportunity

NGVs deserve an equal opportunity to compete in the market based on cost and real-world emission benefits, and government regulators should not effectively mandate a specific clean technology at the exclusion of others. In a joint press release, NGVAmerica, the RNG Coalition, AGA, and APGA support changes to the current regulatory framework to incorporate provisions that more fully account for all the environmental benefits of natural gas vehicles, give meaning to statutory provisions intended to encourage NGVs, and incorporate meaningful incentives for manufacturers to produce natural gas vehicles.

The NGVAmerica statement includes the following comment:

Automakers require powerful regulatory incentives to support the production and sales of new advanced technology vehicles including NGVs. NGVs, both dedicated and dual-fuel, should be provided with the same vehicle production multiplier credits as have previously been, and continue to be, provided to EVs and FCVs.

Their recommendations include:

align the fuel economy and greenhouse gas credit provisions for NGVs;
extend the use of the 0.15 factor for dual fuel vehicles;
amend the driving range and drive-to-empty requirement for dual-fuel NGVs;
provide stronger sales multiplier credits for the production of NGVs;
amend the full-sized pickup truck credits;
provide incentives for gaseous-prep vehicles; and
ensure the resulting rule supports one, unified national program.

“Since the 2012 rulemaking, in addition to the growth of light-truck sales, the nation has experienced growth in the use of ultra-clean renewable natural gas as a waste-to-wheels transportation fuel and the proliferation of NGVs globally,” said Harvey Lamm, co-founder of VNG. “With bi-fuel NGVs sharing a common platform with gasoline vehicles, including the internal combustion engine, they are a low-cost emissions solution for automakers and an attractive option for consumers offering affordability and use of a lower cost, domestic fuel without compromise in vehicle type, functionality, serviceability, safety, fueling time, or range.”

“NGVs and natural gas are a low-emission, domestic fuel alternative,” stated Tom Rastin, Executive Vice President of Ariel. “As the leading producer of natural gas in the world, the U.S. is well-positioned to leverage our abundant natural gas resources to reduce petroleum imports, which still serve about half of our nation’s needs, and advance our global energy leadership. With this rulemaking, the agencies can expand from a single solution pathway emphasizing EVs to a portfolio of solutions to achieve one national standard, harmonize the agencies’ programs, and impactfully reduce emissions and imported petroleum across the US vehicle fleet.”

Documents

The full Notice of Proposed Rule Making (NPRM) can be found in the Federal Register here.

A copy of the formal submission by NGVAmerica, the RNG Coalition, AGA, and APGA can be found at the NGVAmerica Resource Center here.

VNG and Ariel invite you to click here for a review of their full comments.