ACT Expo 2018

The LCFS Is Under Siege in California

November 4, 2014 in Biomethane, CNG, LNG, NGVs, Regulations by Rich Piellisch  |  No Comments

Pending Proposal Could Weaken Support for Natural Gas Vehicles
As Agency Is Said to Base Its Forecasts on Outdated Technologies

A pending overhaul of California’s Low Carbon Fuel Standard could mean lower ratings for natural gas vehicles as a means to reduce greenhouse gas emissions – and hence less support for NGVs when it comes to grants and incentives and the emerging cap-and-trade market for GHGs.

Natural gas vehicles could fare less well if the California Air Resources Board insists on the current CA-GREET 2.0 model.

Natural gas vehicles could fare less well if the California Air Resources Board insists on the current CA-GREET 2.0 model.

The California Air Resources Board – viewed worldwide as a trend-setter in emissions reduction – has proposed sweeping changes to the LCFS, basing many of its conclusions on a new model, dubbed CA-GREET 2.0, for calculating the overall, well-to-wheel GHG impact of natural gas as a vehicle fuel.

NGV advocates want the LCFS to be renewed but not using the current CA-GREET 2.0 model (CA-GREET 2.0 is a second version of the California-modified Greenhouse Gases, Regulated Emissions, and Energy Use in Transportation standard).

Methane Slip Is the Crux

NGVs come out poorly under CA-GREET 2.0 in terms of methane slip – essentially the mount of natural gas that’s unburned and hence goes out the tailpipe of a natural gas vehicle.

CARB's Mary Nichols

CARB’s Mary Nichols

“They’re rushing to make these changes,” says one expert, and “the models that they’re created are inaccurate. They’ve used data from technology that’s obsolete, from vehicles that are no longer on the road.”

The heads of the California Natural Gas Vehicle Association, NGVAmerica and CRNG, the Coalition for Renewable Natural Gas have urged CARB chair Mary Nichols to re-adopt the LCFS early next year (a key meeting is slated for February). But they’d like CA-GREET 2.0 to be set aside, says a CNGVA summary, “pending a more thorough review process and an anticipated influx of new data.”

Too Little Time!

The associations note that CARB released details about CA-GREET 2.0 only last month, and allowed just nine days for industry to respond – a timetable that’s “unnecessary, arbitrary, and capricious,” according to the letter signed by CNGVA president Tim Carmichael, NGVAmerica president Matthew Godlewski, and David Cox, general counsel of CRNG.

“Insufficient time and information have been provided to fully assess the proposed changes,” they maintain.

“By rushing to adopt new CI (carbon intensity) values before significant new natural gas data can be evaluated, CARB risks relying on inaccurate, incomplete or outdated data,” they say.

“The current proposal,” states the letter, “does not take into account new independent, peer-reviewed information about methane leakage that will emerge in the next few months. Instead, CARB is proposing a schedule that guarantees that it will have already adopted a revised CA-GREET model before that information becomes available.”

‘Profound Impacts, International Ramifications’

“It’s critical for CARB to take additional time to ensure the program is based on the strongest-possible scientific foundation,” the letter concludes. “Updating CA-GREET involves very complex and evolving parameters that require proven, fully vetted data and inputs. The modifications that are adopted will likely have profound impacts on development of much-needed alternative fuels and advanced vehicle technologies in California.

“Given that California frequently leads on energy and environmental issues, these changes will have also have important national and international ramifications regarding the best approaches to address climate change,” states the letter to CARB’s Nichols.

“Take the time and do this right,” says F&F’s expert source.

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Source: CNGVC with Fleets & Fuels follow-up






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