MEMORANDUM 

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October 24,2013 

SUBJECT: EPA and VNG.CO Meeting on Tier 3 NPRM 

FROM: Glenn W. Passavant, Office of Transportation and Air Quality ~ 

TO: Public Docket EPA-HQ-OAR-20 ll-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 Powerpoi nt briefing material they provided to EPA. The Powerpoint 

material is attached. 
.co 

Tier 3 and RFS2 Rulemakings 

U.S. Environmental Protection Agency 

October 22, 2013 
To establish a nationwide retail CNG fueling network 

to support NGV market development for light-duty 

fleets as a platform for mass-market consumer 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 of 40% or more per GGE 

New Tier 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 fuel 
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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 sulfur rules 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 that a certification demonstration requirement for new 

vehicle and engine conversions is prudent to maintain a level playing field for 

OEMs and conversion manufacturers."- EPA Aftermarket Certification Rules 

Level playing field for OEM small-volume test group and small-volume 

manufacturer certification exists in most areas, except the 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 all small-volume 

production including OEM, not just small converters _ 

3. Extended Lead Time: OEMs may also need 5-year extended lead 

time to adapt direct injection technologies to CNG 

A true level playing field for small-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 should NOT seek to "upgrade" in the future to match 

California - EPA should provide more certainty and implement 

re ulations consistent with national policies supporting NGVs 

VNG.co 

Renewabl~ CNG can reduce .1/fecyc/e GHGs by up to 90%, 

but feedstock costs are higher. than fossil natural gas 

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 for other biogas feedstocks 

(wastewater treatment plants, manure digesters, etc) would drive 

increased investigation of these sources as well 
Responsibility for RIN Generation Should Remain 

Upstream 

CNG retailers could be discouraged from using biogas feedstock 

if forced 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 comments 
Clean Air Act 

• Cleanest fossil fuel for ICEs 

• Pathway to hydrogen 

• Key alternative for light trucks 

2017-2025 Light-Duty Greenhouse Gas Rulemaking 

• EPA granted 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 of cutting oil imports in half by end of the decade 

• · Increased natural gas use in transportation, alongside biofuels and electricity 

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