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NGVAmerica Submits Comments to U.S. EPA, CARB

On Thursday, NGVAmerica submitted comments in response to the U.S. EPA’s request for information concerning its review of the 2022 – 2025 greenhouse gas standards for light duty vehicles.

The agency is currently revisiting a decision by the Obama Administration under the Mid-term Review.  Shortly before leaving office, the Obama Administration issued a decision to retain the proposed 2022 – 2025 standards. In August, the Trump Administration requested comments on whether the standards should be maintained and specifically requested comments on factors that have changed since the agency adopted the standards in 2012.

NGVAmerica’s comments focused on changes relating to the significant growth in domestic natural gas and the increasing use of renewable natural gas for transportation. These factors point to the potential for natural gas to play a significant role in achieving the objectives of the light duty motor vehicle regulations, i.e., energy conservation, petroleum reductions, reduced emissions, and fuel diversity.  The comments highlighted the advantages of natural gas for powering light trucks and sport-utility vehicles and requested that the agency take steps to increase the regulatory incentives for manufacturers that produce natural gas vehicles. Importantly, natural gas vehicles deliver on the objectives of the light duty regulations without sacrificing the utility that light truck and sport-utility owners have come to expect from this segment of vehicles.

Previous studies, such as the National Petroleum Council’s Future of Fuel, indicate that natural gas vehicles, if mass produced, could prove very economical compared to other options and could capture a significant share of the light duty transportation market in future years. NGVAmerica’s comments included many of the same points raised in comments recently submitted to the National Highway Traffic Safety Administration, which is currently collecting information to inform its decision concerning fuel economy standards for 2022 – 2025 light duty vehicles.

On Friday, NGVAmerica also submitted comments in response to proposed changes the California Air Resources Board (CARB) is planning to make to the Low Carbon Fuel Standard.  CARB Staff unveiled the changes last month at a workshop. Many of the changes appear to unfairly single out conventional and renewable natural gas for changes while leaving other fuels unchanged.  NGVAmerica’s comments urged CARB to provide additional time for industry to review the proposed changes which are based in part of recent emission model changes, the details of which have not been fully released for review.

Lastly, the U.S. Department of Transportation is reviewing its existing regulations and other agency actions to evaluate their continued necessity, determine whether they are crafted effectively to solve current problems, and evaluate whether they potentially burden the development or use of domestically produced energy resources. As part of these reviews, the Department invites the public to provide input on existing rules and other agency actions that are good candidates for repeal, replacement, suspension, or modification. The Department may also hold a public meeting to discuss and consider comments from members of the public.  Comments should be received on or before November 1, 2017.  The full notice can be found here.