Comments of NGVAmerica on the Development of Guidance for the
Reduction of Engine Idling Program
NGVAmerica respectfully submits the following comments related to the development of
Guidelines for the Diesel Engine Idle Reduction Program established under section 756
(Reduction of Engine Idling) of the Energy Policy Act (H.R. 6, P.L 109-58).
Section 756 (b)(4) requires the Administrator of EPA, in consultation with the Secretary
of Transportation “to establish a program to support deployment of idle reduction and
energy conservation technologies”. Section 756 (a)(6) defines an Energy Conservation
Technology to be:
“any device, system of devices, or equipment that improves the fuel economy.”
We believe that natural gas vehicles -- and natural gas heavy-duty engines in particular -qualify as energy conservation technologies for the following reasons;
1) CNG/LNG HD engines displace 100% of the diesel fuel used.
The fundamental purpose of the deployment program established under section 756 is to
accelerate the market penetration of technologies that reduce diesel fuel consumption.
One method would be to increase the efficiency of diesel engines. Another method that
is even more effective in reducing diesel fuel use is to substitute a largely domestic fuel
(e.g., natural gas) for diesel.
Natural gas is a clean, domestically available fuel. Over 96 percent of all the natural gas
consumed in America is produced in North America. NGVs do not use any diesel fuel.
Increased deployment of NGVs and natural gas heavy-duty engines would substantially
reduce diesel fuel consumption, thus contributing directly to the goals for the program
intended by Congress.
2) NGVs and heavy-duty natural gas engines squarely fall within the Priorities of
the deployment program.
Under the deployment program,
“The Administrator shall give priority to the deployment of idle reduction and
energy conservation technologies based on the costs and beneficial effects on air
quality and ability to lessen the emission of criteria air pollutants.”
The displacement of diesel with natural gas in our transportation sector presents an
opportunity to reduce local, regional, and global air pollution. Natural gas vehicles emit
less toxic air contaminants, ozone-precursors, and greenhouse gases than comparable
gasoline and diesel vehicles. According to the Department of Energy, NGVs produce:
 Between 93-95 percent less overall toxics when compared with gasoline and
diesel vehicles
 Heavy-duty trucks and buses fueled by natural gas emit up to 85% less
particulate matter (PM) emissions, cut NOx emission by approximately 50
percent, and reduce greenhouse gases by up to 20 percent.
3) Replacing diesel with natural gas addresses health concerns
Diesel exhaust PM has been classified as a toxic air contaminate by the California Air
Resources Board; the US EPA is expected to announce its classification shortly. In
California, health officials have determined that mobile sources account for 90 percent of
the cancer risk from air toxics and that diesel engines alone represent 70 percent of those
risks. In contrast to the health risks created by diesel emissions, NGVs reduce emissions
of particulate matter by 85% or more. Along with improved overall air quality, NGVs
offer substantial health benefits.
4) CNG/LNG HD engines expected to exceed diesel engine efficiency by 2010
Historically, diesel engines have been more energy efficient than natural gas engines.
That is now changing as natural gas engines are getting more energy efficient and diesel
engines are getting less efficient. A recent study compared natural gas and diesel transit
buses operated by the Washington Metropolitan Area Transit Authority (WMATA). The
2005 WMATA study concluded that, not only were the natural gas buses less polluting
(i.e., the 2004 CNG buses produce 49 percent lower NOx emissions and 84 percent lower
PM emissions than the 2004 diesel buses), but the natural gas and diesel buses had
basically the same fuel economy -- 2.4 mpg, although some natural gas buses had 9%
better fuel economy. Part of the reason for this is the difficulty diesel engine
manufacturers are having meeting EPA’s tighter engine emission standards. For
example, diesel engines meeting the 2002/04 standards reported efficiency losses of as
much as 9 percent. It is widely expected that there will be another loss in diesel engine
efficiency beginning in 2007 as new, even tighter, EPA emissions standards are phased in
by manufacturers, and again in 2010. NGVs will not suffer this loss of efficiency.
For these reasons, NGVAmerica believes that the Guidance issued under Section 756
should recognize that NGVs and, in particular, heavy-duty natural gas engines, are
energy conservation technologies that are eligible under the deployment program to be
established under subsection (b)(4).
For more information, please contact:
Paul Kerkhoven
NGVAmerica
400 N. Capitol St. NW Ste 400
Washington, DC 20001
(202) 824-7363
pkerkhoven@ngvamerica.org
March 30, 2006