Another step in the direction of ‘equalizing’ opportunities for gaseous fuels with petroleum liquids was made at the United Nations in Geneva on 11-12 November 2015 when UNECE Working Party 15 on the Transport of Dangerous Goods (WP.15) passed an amendment allowing the use of gaseous fuels on ADR-certified (dangerous goods) trucks. NGV Global, working collaboratively with the AEGPL (European LPG Association), successfully advocated adding CNG and LPG to the list of approved fuels for ADR trucks. This follows a successful effort by NGV Global in 2014 to include LNG as a fuel for ADR-certified trucks.
The changes in the regulation will come into force in January 2017, which complies with the WP15/ADR two year amendment cycle. Now that the gaseous fuels have been approved, in the interim period, a country may choose independently or in conjunction with other countries through multilateral agreements to certify gaseous fuel trucks before the regulation takes full effect so long as the components and fuel tanks comply with the requirements in UNECE Regulation 110 (and for LPG, R.67). Five European countries have signed a multi-lateral agreement to allow LNG-fuelled ADR trucks in advance of the January 2017 rule coming into force (Belgium, Netherlands, Portugal, Spain and the UK),
The ADR regulation originally was written exclusively for trucks with diesel compression ignition engines. While it did not specifically exclude LNG, CNG and LPG some countries prohibit the gaseous fuels in ADR-certified trucks because they are not specifically allowed by regulation. But the ADR regulation also specified that any leaking fuel must ‘go to the ground’. CNG dissipates upward into the atmosphere. LNG and LPG initially flow to the ground but both fuels, like CNG, dissipate very quickly. As such, the gaseous fuels could not be used legally to fuel an ADR-certified truck including, ironically, those transporting CNG, LNG or LPG.
Though ADR-certified, dangerous goods trucks represent a small part of most truck fleets the rule as it stood prohibited this small but important sector of the truck market to be open to gaseous fuels. For fleets looking at the gaseous fuel option or those with a growing gaseous fuel fleet, prohibitions for ADR trucks presented yet another barrier to NGVs and LPG-fuelled trucks.
NGV Global started the process to amend the ADR for LNG and CNG trucks in 2013, making safety presentations and developing multiple position papers to document the safety history and realities of natural gas as a vehicle fuel. (AEGPL created ‘companion’ safety documents for LPG.) While some of the Contracting Parties (country delegations) were already convinced to use gaseous fuel trucks, there remained some significant questions about the safety of the fuel and particularly, the possible impact of the fuels with the load carried by the truck in the event of an accident. Many other very detailed safety issues and concerns raised about gaseous fuel safety, and particularly cryogenic LNG, had to be addressed and supported with a variety of industry studies, some dating back more than two decades. In the end, the experts from NGV Global and AEGPL ‘partnered in politics’ to educate the WP15 sufficiently to support the use of gaseous fuels in ADR trucks.
Trucks classified as EXII and EXIII, those that carry explosives, still remain off-limits to LNG, CNG and LPG fuelled trucks. NGV Global and AEGPL did not advocate changing this prohibition since it pertains to a very small number of trucks and the debate on this issue and the additional risk analyses required did not merit the effort.
The next issue to focus on at ADR involves regulating the maximum amount of gaseous fuel allowed on road vehicles, not just those that are ADR-certified. ADR regulations now limit liquid fuel on all vehicles (trucks, buses, etc.) to 1500 liters. Although CNG cylinders and LNG and LPG tanks are measured in liters the energy content of the same volume of liquid fuels is much less for gaseous fuels. Additionally, too strict a limit of fuel on-board vehicles could further hamper the industry’s efforts to get more range on gaseous fuel vehicles. Germany raised the issue initially at this last ADR meeting but it will be carried forward to 2016 for further analysis and debate.
All the documents for ADR are on the UNECE website: www.unece.org/trans/main/dgdb/wp15/wp15age.html.
Working Documents are available at: www.unece.org/trans/main/dgdb/wp15/wp152015.html including the NGV Global/AEGPL suggested amendments to allow CNG and LPG as ADR truck fuels and the questions posed by Germany about LNG safety.
Informal Documents are available at: www.unece.org/trans/main/dgdb/wp15/wp152015.html and include the responses by NGV Global and AEGPL to the questions raised about gaseous fuel safety.
Membership and Sponsorship inquiries to support this work by NGV Global can be directed to the Executive Director, Diego Goldin at firstname.lastname@example.org.