NGVAmerica President Dan Gage provided testimony at the U.S. EPA’s hearing on August 25 on the Biden administration’s notice of proposed rulemaking to revise the greenhouse gas emission standards for light-duty vehicles for model year 2023 and later.
The much-expected action proposes to restore emission standards back to levels that are close to what was previously adopted by the Obama administration in 2012 but amended by the Trump administration.
At the public hearing, Gage articulated that renewable natural gas (RNG) should be a key part of any inclusive mix, as RNG is a zero-carbon now solution. The latest data puts the carbon intensity of bio-CNG in California’s system at -16.57 gCO2e/MJ (Q1, 2021), which is the lowest of any on-road motor fuel energy source, including fully renewable electric from solar or wind.
Also, RNG is the dominant natural gas motor fuel. Last year, RNG displaced conventional natural gas derived from fossil sources as the main on-road NGV fuel source nationwide. In California, with its Low Carbon Fuel Standard Program, 92% of NGV motor fuel is from renewable sources.
Natural gas motor fuel is increasingly sustainable and carbon-free. By 2030, 80% of natural gas on-road motor fuel in the U.S. will be derived from renewable sources, rising to 100% by 2050.
“NGVAmerica agrees that climate change is cumulative; the longer we wait, the harder it gets to solve,” testified Gage. “There is no single perfect, affordable and immediate solution to addressing transportation related climate change emissions. Thus, all clean options must be advanced to make a collective difference…beginning today.”
Gage warned against rolling back improvements advanced by the previous administration that removed barriers to natural gas certification and incentivized expanded natural gas vehicle production in the form of sales multipliers
“These sales multiplier incentives should not be eliminated, but reinstalled and expanded, to advance every available, affordable, and scalable clean powertrain solution,” Gage stated. “Providing significant renewable natural gas vehicle incentives to automakers will allow for flexibility to meet the varied needs of fleets.”
He shared how expanded deployment of affordable and available zero-carbon RNG trucks and work vans would meet the administration’s goal of getting more clean replacement vehicles on the road right away, impacting frontline communities sooner, and that an established, mature and varied RNG refueling infrastructure already exists coast to coast.
“All emissions matter…well to wheel and mine to mile,” concluded Gage. “EPA’s regulations must be amended to ensure that manufacturers have greater reason to produce ultra-low-carbon motor vehicles that operate on biofuels, not just vehicles that have so-called zero tailpipe emissions.”
Detailed written comments on the EPA proposed rule are due by September 27.