NGVAmerica Comments on Phase 2 Greenhouse Gas and Fuel Efficiency Proposal

On Thursday, NGVAmerica submitted comments on the U.S. Environmental Protection Agency (EPA) and National Highway Traffic Safety Administration (NHTSA) proposed greenhouse gas (GHG) and fuel efficiency requirements for new heavy-duty vehicles.  The comments commended the agencies for their hard work in crafting the proposal.  NGVAmerica also indicated its support for the objectives of the rulemaking: reduced greenhouse gas emissions, fuel savings and petroleum reductions.  The rules take effect starting in 2019 for trailers and 2021 for engines and trucks. The Phase 2 rulemaking (Phase 1 rules were finalized in 2011) includes requirements for engines, trailers, and complete trucks and sets different levels of stringency for different categories of vehicles (e.g., large pickup trucks, vocational vehicles, transit buses, tractor trailers, etc.).

With respect to NGVs, we commented on nearly a dozen issues.  We indicated our support for the continued use of the global warming factor for methane (i.e. GWP 25) that EPA uses for numerous other programs.  We supported the calculation of fuel economy that is based on CO2 emissions, something that gives NGVs a small advantage over gasoline and diesel engines, and the continued ability of engine manufacturers to offset methane and nitrous oxide emissions with carbon dioxide reductions.  We expressed our support for the decision to retain the way engines are classified and regulated—which means that larger natural gas engines will continue to be regulated along with and subject to the same requirements as diesel engines.

With respect to aftermarket conversions, we urged the agencies to continue to provide flexibility for small business that provide these systems.  The Phase 2 rules, as proposed, are a change from Phase 1, which exempted small business manufacturers of aftermarket systems from having to comply with the greenhouse gas regulations.  Under the Phase 2 rules, it is our understanding that aftermarket conversions will be covered beginning in 2023 (engines are covered starting in 2021 but there is a one-year delay for alternative fuel systems and an additional one-year delay for small businesses).  NGVAmerica also commented on the proposal to restrict the sale of gliders (new vehicles equipped with older engines and drivetrains).  We urged EPA to retain this option for alternative fuel systems and to also consider an increase on the number of alternative fuel systems that qualify.

For more details on the comments made by NGVAmerica or to receive a copy of our comments, please contact Jeff Clarke at 202.824.7364 or jclarke@www.ngvamerica.org.