MEMORANDUM lNTEDSTAlES BNR:Ht£NTAL PROIB.,""TD'D' AGJ!N;Y NAlD'W.. vt:HI CLE PKJ FLB.. EMI SSIO>JS L..AB:RA.TrnY 2536 PLYMOUTH ROAD**~ ~**  MCl£liN**481~2498**

October24,2013 SUBJECT: EPA and VNG.CO Meeting on Tier 3 NPRM FROM: Glenn W. Passavant, Office ofTransportation and Air Quality**~** TO: Public Docket EPA-HQ

-OAR-20ll-0 135 Staff from EPA and VNG.CO met by video on October 22, 2013. EPA was represented by Bill Charmley, Mike Sabourin, Robin Moran, Mike Olechiw, Alan Stout, Tad Wysor, Jeff Herzog, and Glenn Passavant. VNG.CO was represented John Atkinson, Paul Kouroupas, and Susan Lent. The purpose of the meeting was to discuss EPA's Tier 3 NPRM and for VNG.CO to discuss the comments they submitted to the EPA docket. The discussions at the meeting focused on the VNG.CO comments to the docket as expounded upon in the Powerpoint briefing material they provided to EPA. The Powerpoint material is attached.

# .co

Tier 3 and RFS2 Rulemakings U.S. Environmental Protection Agency October22, 2013

# To establish anationwide retail CNG

# fueling network to support NGV

# marketdevelopmentfor light-duty fleets as aplatformfor mass-marketconsumer use.• 2017-2025 GHG and CAFE regulations offer incentives to OEMs to increase production of NGVs
• Fueling infrastructure investment ramping up- over 1,300 CNG stations nationwide
• Clean Energy selling renewable CNG blends (link)
• Ford producing CNG-prepped F-150 (link)
• GM producing bi-fuel Chevy Impala (link)
• AT&T has deployed nearly 5,500 NGVs in its fleet, plans for thousands more (link) Consumer

.... interest 

# 1
Fleet Government support

Fueling infrastructure adoption investment ' Expanding

# ~ vehicle options

### NGVs Have Unique Role, Potential to Achieve Emission Goals Light-duty NGVs can play unique role in supporting EPA clean air goals • Cleanest fossil fuel= lowest emissions from increasingly-efficient ICE vehicles • Synergies with hydrogen FCEVs (as noted in 2017-2025 GHG rules) • Key alternat

_ ive for light trucks, which may lack electric options NPC and NAS studies have concluded that NGVs have the greatest potential of all alternative fuel vehicles to achieve mass market adoption • ICE compatibility- no technology obstacles • Potential for rapid cost declines with mass production • Compelling fuel cost savings of40% or more per GGE NewTier 3 and RFS2 rulemakings should support and accelerate nascent momentum for NGVs • Avoid adding unnecessary costs to NGV production and CNG distribution • Promote production and use of biogas as an ultra-low carbon transportation fuelCD C 

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### Gasoline • Gasoline is used only for vehicle fuel • Sulfur content of gasoline must be reduced for Tier 3 emission controls • Fuel composition determined at limited 

### # of refineries, clear point of regulation • Established process, costs for reducing sulfur content 

### CNG • Natural gas has many nontransportation end uses • No evidence that CNG sulfur content would impact Tier 3 emission controls • No data on average sulfur content of natural gas, likely to vary regionally • No info on means or costs to reduce CNG sulfur content No evidence that sulfurrules are necessary for CNG, and unknown costs could stifle CNG fueling development**~** 

## VNG.co

### EPA Should Establish A Level Playing Field for SmallVolume Manufacturing

"EPA also believes thata certification demonstration requirement fornew vehicle andengine conversions is prudent to maintain a levelplaying field for OEMs andconversion manufacturers."- EPAAftermarket Certification Rules Level playing field for OEM small-volume test group and small-volume manufacturer certification exists in mostareas, 

### exceptthe following: 1. Small-Volume Definition: Should remain 15,000 vehicles/year (not 5,000) and apply to both SVMs and Small-Volume Test Groups 2. 

### OBD Testing: Streamlined - OBD testing for allsmall-volume production including OEM, notjust small converters
_ 3. 

### Extended Lead Time: OEMs may also need 5-year extended lead time to adapt direct injection technologies to CNG A true levelplaying field forsmall-volume production could encourage market entry by more OEMs, more vehicle models, more innovation

### EPA Should NOT Commit to Matching CARB OBD Testing California OBD Rules are Costly Today and Uncertain Tomorrow
. • CARB certification imposes unnecessary additional OBD testing and documentation requirements, increasing costs and time and limiting NGVs • CARB is now explicitly trying to mirror EPA 2011 aftermarket changes, including reduced OBD testing - 

### who's following who? • Improved CARB proposals still allow only 4
. ,500 vehicles under smallvolume conversion rules, and only allow for converters- 

### NOT OEMs • Still uncertainty over current CARB proposals, not yet finalized - discussions may continue into 2014 • CARB streamlining proposal "sunsets" after 2017, leaving total uncertainty as to what OBD rules will be in place when Tier 3 takes effect

1:] Tier 3 rules shouldNOTseek to " upgrade "in the future to match California - EPA shouldprovide more certainty and i mplement re ulations consistent with nationalpolicies support i

ng NGV s 

## VNG.co

### Renewabl~ 

## CNG can 

## reduce
.1/fecyc/e 

## GHGs by

## up to 

## 90%, butfeedstock

## costs are higher
.than fossil naturalgas VNG supports reclassifying landfill-derived biogas CNG from "advanced" to "cellulosic" biofuel RINs (03/07) 1. Makes sense based on very high landfill cellulosic content 

### 2. Helps close cost gap by increasing value of RINs 

### 3. Helps ensure RFS2

.goals can be met despite delays in cellulosic ethanol development * 70% cellulosic threshold forotherbiogas feedstocks (wastewatertreatmentplants, manure digesters, etc) would drive increased investigation ofthese sources as well

### Responsibility for RIN Generation Should Remain Upstream
CNG retailers could be discouraged from using biogas feedstock ifforced to take on significant new administrative responsibilities 

### Responsibility for RIN generation should remain with biogas producers and not shifted downstream to CNG retailers • CNG retailers lack experience with lifecycle feedstock tracking -would require significant resources, new personnel • Much easier administratively to regulate limited number of biogas producers vs._ hundreds or thousands of CNG retailers • Supported by the Coalition for Renewable Natural Gas in written commentsClean Air Act • Cleanest fossil fuel for ICEs • Pathway to hydrogen • Key alternative for light trucks 2017-2025 Light-Duty Greenhouse Gas Rulemaking • EPAgranted new incentives for NGVs in GHG rule • Tier 3 and RFS2 can and should reinforce, not undercut this support Executive Order 13563 • NGV industry promotes economic growth and innovation as well as clean air • EPA must use "least burdensome tools" for regulatory ends, flexible approaches President Obama's Blueprint for a Clean and Secure Energy Future • Goal ofcutting oil imports in half by end ofthe decade • · Increased natural gas use in transportation, alongside biofuels and electricity



## I Contact Paul Kouroupas, pkouroupas@vng.co , 973-886-7675 

## I