NGV Industry Overview Report v9X

8/12/2019 NGV Industry Overview Report v9X

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For more information, visit www.ngvevent.com

Natural Gas VehicleMarket Whitepaper USA2013-2014

Whitepaper highlights include:

NGV USA Market Overview:

Comprehensive analysis of theNorth American NGV Market

Government Policies:

How they will impact the NGVmarket over the next 5 years

Converting to Natural Gas:

Key considerations to addresswhen converting your fleet to NGVs

Infrastructure Development:

How to successfully plan and buildNGV infrastructure


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WELCOME

For more information visit www.ngvevent.com NGV INDUSTRY OVERVIEW | 2

Welcome

Dear Colleague

Thank you for your interest in this FC Gas Intelligence Whitepaper on the Natural Gas Vehicle market in NorthAmerica, 2013-14, I hope you find it valuable.

Natural Gas Vehicles (NGV) are at a seminal moment in the United States currently, with a range ofstakeholders driving the development of the market. To get a thorough overview the report interviewed over20 industry experts, drawing their combined expertise into this document to better inform your strategiesover the next few years.

This Whitepaper is only the beginning of the debate on Natural Gas Vehicles, it has been created inconjunction with the 3rd Natural Gas Vehicle USA Conference & Exhibition (June 11-13, Houston) more infocan be found here www.ngvevent.com

I hope you find the report useful and I look forward to speaking to you soon,

With very best wishesJoshua Bull

Sector Head | FC Gas Intelligence

[email protected]


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ABOUTFCBUSINESSINTELLIGENCE


About FC Gas Intelligence

A business intelligence and networking company we help leading corporations define their future strategyand direction, develop growth opportunities and solve the problems facing their sectors. The engines of ourbusiness are growth and change. We focus on two types of industry:

Those arising from technology developments which are moving into full global commercialisation. Those needing to change in order to respond to disruptive technologies or global events.

Our aim is to provide companies with insights into strategic options for the future in order that they cancapitalise on opportunity.

Disclaimer

FC Business Intelligence Ltd and its partners prepared the information andopinions in this report. FC Business Intelligence has no obligation to tell youwhen opinions or information in this report change. FC Business IntelligenceLtd makes every effort to use reliable, comprehensive information, but it makesno representation that the information is accurate or complete. In no eventshall FC Business Intelligence Ltd and its partners be liable for any damages,losses, expenses, loss of data, loss of opportunity or profit caused by the use ofthe material or contents of this report.

No part of this document may be distributed, resold, copied or adapted

without FC Business Intelligence Ltd s prior written permission.

FC Business Intelligence Ltd 2013

Author


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CONTENTS


Contents

Welcome . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

About FC Gas Intelligence . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

List of Tables . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-8

Chapter 1: NGV Industry Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

1.0 Market Size and Growth Forecasts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .9

1.1 Growth drivers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

1.2 NGVs on the Road . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 131.3 Locations of Existing CNG and LNG Stations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

1.4 Proposed expansion ofCNG and LNG fueling networks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

1.5 Expansion of Small and Midsize LNG Liquefaction Plants . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

1.6 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

Chapter 2: Government policies: How they will shape the NGV market over the next 5 years . . . . .22

2.0 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

2.1 Policy in context . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

2.2 Subsidies and tax incentives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 222.3 Procurement policy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

2.4 CAF standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

2.5 Environmental regulation: potential risk? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

2.6 Export policy: potential risk? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

2.8 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

Chapter 3: Converting to Natural Gas, Vehicle issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .28

3.0 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

3.1 Passenger automobiles . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

3.2 Light and medium duty trucking vehicle options . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 293.3 State subsidies for light-duty NGVS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

3.4 Heavy duty trucking . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33

3.5 Factors to consider in HD fleet conversions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34

3.6 State subsidies for heavy-duty fleet conversion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

3.7 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37

Chapter 4: Building Dedicated Fuelling Infrastructure, CNG and LNG . . . . . . . . . . . . . . . . . . . .38

4.1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38

4.2 Basic cost considerations, CNG compared to LNG . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38

4.3 Design, planning, and siting of CNG fuelling stations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

4.4 Design, planning, and siting of LNG fuelling stations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42

4.5 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44


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FIGURES


Figures

Figure 1 Natural gas consumption by sector, 1990-2040 (trillion cubic feet) . . . . . . . . . . . . . . . . . . . . . . 9

Figure 2 U.S. Natural Gas Vehicle Fuel Consumption MMcf . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

Figure 3 Average diesel, gasoline, and CNG prices, 2000-2012 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

Figure 4 Price differential CNG to diesel, by state . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

Figure 5 PCT. Growth in public access CNG stations 7/11-8/13. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

Figure 6 Regional Transportation Corridors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14Figure 7 Locations of CNG stations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

Figure 8 Locations of LNG Stations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

Figure 9 United States truck traffic volumes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

Figure 10 Projected expansion of Trillium CNG station network, 2013-2016 . . . . . . . . . . . . . . . . . . . . . . 17

Figure 11 Projected expansion of Loves CNG network . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

Figure 12 Projected rollout of Clean Energys Americas Natural Gas Highway of LNG and LCNG

stations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

Figure 13 Projected network of LNG stations proposed by Shell and TravelCenters of Americapartnership . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

Figure 14 Blu LNG operational and pending LNG fuelling network (as of end 2013) . . . . . . . . . . . . . . 19

Figure 15 Small and Mid Scale LNG Liquefaction plants* . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

Figure 16 Calculation of light-duty truck payback, based on various fuel price and truck premium

assumptions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

Figure 17 Map of states offering various incentives for light-duty CNG vehicles . . . . . . . . . . . . . . . . . . 32

Figure 18 Natural gas engine comparison-- power (hp) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33

Figure 19 Natural gas engine comparison torque (ft-lb) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33Figure 20 Sample calculation of expected payback for HD fleet conversion . . . . . . . . . . . . . . . . . . . . . . 34

Figure 21 Sample CNG range calculation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35

Figure 22 Calculation of Heavy-duty truck payback, based on various fuel price and truck premium

assumptions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

Figure 23 Heavy-duty incentives, Canada and US (as of August 2013) . . . . . . . . . . . . . . . . . . . . . . . . . . . 37

Figure 24 GE CNG in a Box . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41

Figure 25 GE LNG in a Box . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43

Figure 26 Micro LNG . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43


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TABLES


List of Tables

Table 1 CNG average prices per region . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11

Table 2 Reduction of pollutants from CNG use, as compared with reformulated gasoline. . . . . . . . . 1 2

Table 3 Small and Mid Scale LNG Liquefaction plants in the United States* . . . . . . . . . . . . . . . . . . . . . .20

Table 4 LNG Export facilities approved . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .26

Table 5 Home fuelling specifications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .29

Table 6 Ford CNG model options (as of model year 2014) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .30Table 7 Chrysler CNG model options (as of model year 2014) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .30

Table 8 GMC and Chevrolet CNG model options (as of model year 2014) . . . . . . . . . . . . . . . . . . . . . . . .30

Table 9 Summary of state incentives for light-duty CNG vehicles. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .31

Table 10 Heavy-Duty engine options . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .33

Table 11 Weight diesel truck compared to CNG truck and LNG truck (full tanks in lbs) . . . . . . . . . . . . .35

Table 12 CNG to LNG compared . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39


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EXECUTIVESUMMARY


FC Gas Intelligences Natural Gas Vehicles MarketReport USA 2013-2014 provides an up-to-the-minute summary of current conditions in thisfast-growing market segment. The reportsfour chapters summarizes the latest businessintelligence vital to understanding issues currentlyconfronting stakeholders in this market, andprovides direct guidance for fleet managers lookingfor first-hand advice on key issues to consider whendeciding whether to switch to cheaper, cleaner-burning natural gas.

Chapter 1: NGV USA Market Overview:

Comprehensive Analysis of the North AmericanNGV Market

Natural gas has significant potential to transformthe transportation sector, particularly for fleetsand commercial trucking, due to its cheaper, lessvolatile price, compared diesel or gasoline. The fuelis largely sourced in North America, in contrast topetroleum-based fuels, which are largely sourcedfrom politically unstable and potentially hostileregions of the world, especially the Middle East.

The fuel is also cleaner burning than traditionaltransportation fuels, and can help provide a bridgeto a greener, lower-carbon future.

The chapter lays out in detail how the numberof CNG and LNG public access fuelling stations isexpanding rapidly, with several companies rollingout new NG infrastructure. Detailed informationis provided about ambitious expansion plans,launched by companies such as Trillium and Love

Travel Stops, in the era of CNG infrastructure, andClean Energy, Shell, and ENN- Blu LNG on theLNG side. In partnership with Pilot Flying J Truck S,Clean Energy is also exploring LCNG options. The

net effect of these expansion plans is that somefleetsparticularly heavy-duty trucks servicingmajor interstate transportation corridors may soonbe able to convert to natural gas without having todevelop independent fuelling infrastructure.

Chapter 2: Government Policies: How they will

impact the NGV market over the next 5 years

Federal and state government policies havebeen crucial to fostering the development of NGas a transportation fuel. Stakeholders currentlyoperating in this market, as well as companies

considering undertaking fleet conversions, need tounderstand how government policies will continueto shape the future development of the NGV sectorin both positive and potentially negative waysover the next five years. The chapter provides anoverview of current federal and state policies topromote NGVs, and provides information on whatgovernment and private resources are available forgetting the latest information about these rapidlyevolving policies. Detailed discussion follows oftwo significant policy areas environmental

regulation, both state and federal, and exportpolicy that could thwart or at minimum slowdevelopment of NGVs. Understanding potentialpolicy risks is important for companies undertakingor continuing significant investments in NGVs orinfrastructural development.

Executive Summary


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EXECUTIVESUMMARY


Chapter 3: Converting to Natural Gas: Key

Considerations to address when converting

your fleet to NGVs

The higher relative costs of NGVs comparedto traditionally-fuelled vehicles has thus farpresented a major obstacle to wider use of NGas a transportation fuel. This chapter summarisesthe current state of the NGV market. OEMs havestarted to offer a wider range of NG options,from automobiles, to vansboth passenger andcargoand light and medium-duty truck options.These vehicles cost more than conventionally

fuelled models, but some of these costs can beoffset by state incentives available for converting toNG. All major heavy-duty truck manufacturersnow offer NG options, either in CNG or LNGformats, prodded by customers responding to thepotential significant fuel costs savings. The chapterwalks through specific examples of how to evaluatethe value proposition for fleet conversions, lookingat both light-duty, and heavy-duty, examples.

Chapter 4: Infrastructure Development: How to

successfully plan and build NGV infrastructure

Infrastructural considerations continue to loom largein decisions to convert all or part of a fleets vehiclesto NGV. The future U.S. NG infrastructure will combinea network of CNG, LNG, and LCNG stations.This chapter analyses issues fleet managers needto consider in deciding whether to opt for CNG ofLNG, based on where their fleets will operate, andwhat their range needs are. Although more CNGand LNG infrastructure is continually coming on-line, most fleets must still construct or secure access

to independent fuelling infrastructure, as existingpublic access infrastructure alone cannot supportfleet range needs. This chapter discusses the issuescompanies must consider when deciding whether,where, and how to construct CNG or LNG fuellingstations. Infrastructural specialists are expandingtheir product offerings, focusing on modular, andlower-cost options that reduce the necessary up-frontinvestments and also lower on-going operational andmaintenance costs, for companies constructing both

CNG and LNG fuelling infrastructure.

Executive Summary


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INDUSTRYOVERVIEW


Chapter 1: NGV Industry Overview

1.0 Market Size and GrowthForecastsPetroleum-based fuels currently dominate the U.S.transportation market, and this lack of fuel diversitymakes this market particularly vulnerable to priceshocks. The United States currently consumes 35billion gallons of diesel fuel per year. Analysts disagreeabout how much of this current energy demandcould be displaced by cheaper alternative fuels such

as natural gas (NG), particularly in the industrial,power generation, and transportation sectors.

Citigroup forecasts NG demand in transportationalone to reach 2.2 billion cubic feet per day (Bcf/d) by2020, while a Reuters poll of analysts is less bullish,expecting NG demand in this sector to reach only1.2 Bcf/d over the same period. The United StatesEnergy Information Administration (EIA) predictsa gradual rise in NG usage in the transportationsector over the next decade, as shown in Figure 1,as a more comprehensive NG sourcing and fuellinginfrastructure is developed, comprising bothcompressed natural gas (CNG) and liquefied naturalgas (LNG).

Figure 1 Natural gas consumption by sector, 1990-2040 (trillion cubic feet)

The use of NG as a transportation fuel has increasedsteadily over the last decade, reaching 32,000 Millioncubic feet (MMcf ) in 2012. Most of this consumptionis currently concentrated in the heavy-duty truckingsector. The American Clean Skies Foundationsuggests that NG provides a promising opportunityto diversify fuel sources for both the heavy andmedium duty trucking sector, which, taken together,account for 22% of the U.S. transportation sector s fuel

use. This diversification would come with anotherbenefit, for the cost of fueling with NG is substantiallycheaper than buying petroleum-based fuels, evenwhen necessary costs are included, both buyingrelatively more expensive NGVs, and developingfueling infrastructure, Fleet operators have a potentialopportunity to capitalize on a major cost-savingopportunity, since fuel accounts for their second-highest cost.


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INDUSTRYOVERVIEW


Figure 2 U.S. Natural Gas Vehicle Fuel Consumption MMcf

1.1 Growth drivers

Fuel price

The principal factor driving growth in interest in NGVsis the lower overall price of NG compared to the costof either gasoline or refined diesel fuels. Over the lastdecade, NG prices have dropped dramatically as new

North American sources of supply have opened up,with the United States moving from a potential NGimporter to a potential significant NG exporter overthis time period.

Oil prices, by contrast, have been especially volatileover the same time period. Since 2000, refined dieselprices as measured by Diesel Gallon Equivalents(DGEs) have always exceeded NG prices, sometimes

by as much as $2, but usually by at least $1.50, perDGE. Similarly, gasoline prices have always exceededNG prices, when measured by Gasoline Gallon Equivalents (GGEs), by as much as $1.50 per unit.

Figure 3 Average diesel, gasoline, and CNG prices, 2000-2012

Source: Clean Cities Alternative Fuel Price Report, July 2013


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INDUSTRYOVERVIEW


Politically stable source of supply

In addition to the comparative price advantage, NG

supplies are more stable and certain, and virtuallyall demand can be supplied either domestically, orby turning to Canada or Mexico; the three countriesare linked in a fully integrated NG transportation anddistribution system. About 85% of the NG consumedin the United States is sourced domestically, fromone of the 32 U.S. states that currently produce NG.Overall, 97% of the NG used in the U.S. comes eitherfrom the United States, Canada, or Mexico.

By contrast, oil is sourced from politically unstable or

potentially hostile places, including Latin America,Russia, and especially the Middle East. Politicalinstability in the Middle East often translates intoprice volatility and also raises periodic concernsabout supply interruptions. Increased use of NGwould translate into lessened dependence on energyimports from these politically unstable parts of theworld.

Price stability

In addition to their more attractive absolute pricelevels, NG prices also have another advantage forcorporate planning purposes in that they have inrecent years traded in a much narrower band thaneither diesel or gasoline prices, with the prices varyingsince 2000 about $1 from lowest to highest price.Since late 2004, this price spread has been eventighter, varying by no more than $0.75.

It has not always been the case that NG prices havetraded in such a narrow band, and in fact, until

technology increased the domestically producedsupply, NG prices had been among the most volatilecommodities traded on the New York MercantileExchange (NYMEX). Future forecasts of NG supplysuggest that future volatility will follow the recentpattern of tighter trading spreads.

Regional price variations

As Table 1 indicates, CNG currently has a lower

average price than diesel for all regions of the country,with the largest difference ($1.83 per DGE) being inthe Rocky Mountain region. CNG costs on averageabout $1.52 less than diesel on a DGE basis.

Table 1 CNG average prices per region

Region CNG Price ($/DGE) Diesel Price ($)

New England $2.86 $4.07

Central Atlantic $2.48 $3.81

Lower Atlantic $2.24 $3.82

Midwest $2.08 $3.86

Gulf Coast $2.26 $3.82

Rocky Mountain $2.03 $3.86

West Coast $2.71 $4.08

National Average $2.39 $3.91



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INDUSTRYOVERVIEW


Figure 4 illustrates price differentials by state for CNGrelative to diesel. In this map, negative numbers

represent prices for CNG lower than prices for diesel.States not highlighted with a colour did not have anyCNG data points in the latest Clean Cities Alternative

Fuel Price Report, published in July 2013. For all statesfor which pricing data are available, CNG prices were

cheaper than diesel, with the most favourable relativeCNG prices found in states located in the Midwest,Rocky Mountain, and West Coast regions.

Figure 4 Price differential CNG to diesel, by state

CNG Price Difference

Relative to Diesel

($1.99) - ($1.50)

($1.49) - ($0.95)($2.30) - ($2.00)

($1.99) - ($1.50)

($0.94) - ($0.55)


Environmental benets

There are considerable environmental benefitsto wider adoption of NG as a transportation fuel,whether in CNG or LNG form. The United States

Environmental Protection Agency (EPA) recognizesthat natural gas vehicles (NGVs) produce lower levelsof harmful emissions, including greenhouse gases,carbon dioxide, nitrogen oxide, particulate matter,and toxic and carcinogenic pollutants. The exactdegree of emissions benefits depends on the typeand model of the vehicle used, as well as the choiceof the conventionally fueled vehicle benchmark. TheAlternative Fuels Data Center (AFDC) of the UnitedStates Department of Energy (DoE) provides tools forperforming detailed emissions comparisons. Many

fleet operators are as attracted to NGs potential toenable them to meet their emissions targets as they

are to the potential for fuel cost savings compared tousing diesel or gasoline.

Table 2 Reduction of pollutants from CNG use, ascompared with reformulated gasoline

Volatile Organic Compounds 10%

Carbon Monoxide 20-40%

Nitrogen Oxides 0%

Particulate Matter 80%

Source: A Full Fuel-Cycle Analysis of Energy and Emissions Impactsof Transportation Fuels Produced From Natural Gas, Wang, M.Q.and Huang, H.S., 1999


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1.2 NGVs on the Road

The DoE as of September 2013 estimated that about112,000 NGVs operate in the United States.Market observers say that these DoE figures lag theactual state of play, and that the number of NGVscurrently on the road is probably approaching150,000. Transit buses currently form the largestcategory of NGVs, and are powered by either CNG orLNG. Waste collection vehicles comprise the secondlargest category of NGVs, with roughly half of all suchvehicles fueled by NG. Airports are the third largestNGV users, with about 35 using NGVs, either byoperating their own fleets or promoting the use ofprivate fleets that burn NG.

Wider use of NG in both short-haul fleets andlong distance trucking is being facilitated by thedevelopment of CNG, LNG, and LCNG fuelingnetworks. Technological innovation is producing moreaffordable light-duty, medium-duty, and heavy-dutyNG truck options, as well as NG-fueled passengervehicles, largely for fleet use, although the premium

for all such vehicles remains high. These premiumsare expected to drop as demand for these vehiclesincreases, but even on current estimates, a viablemodel for heavy-duty trucks driving 125,000 miles ayear suggests that payback on CNG fleet conversioncan occur in fewer than 2 years (as described morefully in section 3.__ below).

1.3 Locations of Existing CNGand LNG Stations

CNG stations

As of September 4, 2013, 602 public access CNGstations operate across the United States, and633 private access stations. These stations aresubstantially concentrated regionally. California andUtah have been at the forefront of adopting NG asa transportation fuel, and now each of these twostates is covered with a network of stations, with 157stations operating in California, serving a population

of about 38 million, and 42 in Utah, serving apopulation of approximately 2.9 million. (The stateof Utah owns natural gas production facilities andhas promoted NG use in transportation; in contrast toother states, Utah has eschewed direct subsidies tothis end, and has instead concentrated on buildingNG infrastructure.)

Other states with significant concentrations of CNGstations include the key NG producing states ofLouisiana, Oklahoma, and Texas, as well as urban

states such as New York. Pennsylvania and Ohio haveshown the highest growth rate in building CNGstations in the last two years, and now have 21 and 13public access stations operating, respectively.

Figure 5 PCT. Growth in public access CNG stations 7/11-8/13

Source: NGV Today, August 19, 2013, p. 9


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Figure 7 Locations of CNG stations

Source: http://www.afdc.energy.gov/locator/stations/results?utf8=&location=&filtered=true&fuel=CNG&owner=all&payment=all&ev_level1=true&ev_level2=true&ev_dc_fast=true&radius_miles=5

Some companies have stepped in to make publiclyavailable via the internet not only station location

and tracking tools, but other relevant information.CNGprices.com, for example, supplies up-to-the-minute information on CNG prices at a particularstation, as well as crowd sourced information aboutstation reliability, opening hours, and paymentinformation.

http://www.cngprices.com/index.phpCNGnow.com incorporates a GPS application. http://

www.cngnow.com

LNG suppliers, such as Blu LNG, have incorporatedstation finder features in their websites, which alsoinclude pricing information, opening hours, andpayment options. http://blulng.com

Figure 8 Locations of LNG Stations

Source: http://www.afdc.energy.gov/locator/stations/results?utf8=&location=&filtered=true&fuel=LNG&owner=all&payment=all&ev_level1=true&ev_level2=true&ev_dc_fast=true&radius_miles=5


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1.4 Proposed expansion of

CNG and LNG fueling networks

In the past two years, several companies haveannounced ambitious efforts to construct public

access NG infrastructure. These plans generally closelytrack major U.S. trucking routes and patterns. In

general, to date CNG fuelling station networks havebeen designed largely to serve local and regionalfleets. The thrust of LNG station development hasbeen to connect these regional hubs.

Figure 9 United States truck traffic volumes

CNG stations

In the CNG area, for example, Trillium announcedan expansion project in June 2013 to constructand open 101 new CNG stations in 29 states within

three years. This project includes plans to build newstations in states that already have extensive CNGinfrastructure-- including California, New York, Ohio,

and Pennsylvania, Texasand will also locate manynew stations in states that currently have few publicaccess CNG stations, including Florida and Georgia,

but are nonetheless high-volume parts of current U.S.trucking networks.


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Americas Natural Gas Highway

Clean Energy Fuels, the largest provider of NG fuel

for transportation in North America, in July 2011 wasthe first private company to jump aggressively intosupplying NG infrastructure when it announced plansto construct Americas Natural Gas Highway, a networkof 150 public access LNG-fuelling stations, across 33states. So far, about 70 stations have been completed,although rollout is proceeding slower than originallyanticipated, partly due to Clean Energys desire tosecure anchor tenants before construction of newfacilities. Using two liquefaction plants, one plannedand one operational, Clean Energy will supply both

stages of the supply chain, production and marketing.

Clean Energy has also entered into a partnershipwith Pilot Flying J Truck Travel Centers, which willallow Clean Energy to add NG fuelling options to theservices already offered at Pilot Flying Js extensivenetwork of existing truck stops throughout the UnitedStates. Clean Energy also intends to add CNG-fuellingcapacity at selected locations on the network, as andwhere it determines there will be sufficient demand tosupport such facilities.

Figure 12 Projected rollout of Clean Energys Americas Natural Gas Highway of LNG and LCNG stations

Source: Clean Energy Fuels

Shell and TravelCenters of America partnership

Shell and TravelCenters of America announced in April2013 that they would partner to provide a nationwidenetwork of LNG fueling stations for heavy-duty roadtransportation customers. The companies intend toconstruct at least two LNG fueling lanes and a storagefacility at 100 existing TravelCenters of America orPetro Stopping Centers full service travel centerslocated along the U.S. interstate highway system.Shell anticipates that the first of these stations will

be operational within a year and intends to make it apriority to develop LNG fueling infrastructure alongthe main trucking corridors.Shell is also investing in both LNG liquefaction andrefuelling infrastructure, and plans to build two

liquefaction plants. These will supply the basis fortwo new LNG refuelling networks, in the Gulf CoastCorridor (Texas and Louisiana) and the Great LakesCorridor. These Shell-fueled networks have thepotential to link up with planned or existing cleantransportation corridors, including the Texas Triangleand the I-75 Clean Transportation Corridor. Marketobservers suggest that Shells entry into the NG marketis serving as a wake-up call signaling the growing

importance of NG as a transportation fuel, as Shellis a major multinational player with the scale andresources to transform this domestic U.S. LNG marketsubstantially.


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Figure 13 Projected network of LNG stations proposed by Shell and TravelCenters of America

partnership

Source: Shell

ENN initiatives

Chinese-owned ENN is also investing heavily in U.S.LNG fuelling infrastructure, with plans to build up

to 500 LNG stations. ENN has partnered with a small

Utah company, CH4 Energy, to create a joint venturetrading as Blu LNG. ENN has ambitions of building

LNG plants in the future.

Figure 14 Blu LNG operational and pending LNG fuelling network (as of end 2013)

Source: Blu LNG, http://blulng.com/station-finder/


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1.5 Expansion of Small andMidsize LNG Liquefaction Plants

Crucial to the rollout of a wider use of LNG as atransportation fuel is increasing geographic access

to its supply, which is partly being achieved bydeveloping small and midscale LNG liquefaction

infrastructure. Gas producers, suppliers, utilities, andpublic companies are planning and building newfacilities.

Figure 15 Small and Mid Scale LNG Liquefaction plants*

*Planned and operational small and mid scale liquefaction facilities in the United States, where the location has been made public ordisclosed directly to FC Business Intelligence.

Table 3 Small and Mid Scale LNG Liquefaction plants in the United States*

P = Planned E = Expansion O = Operational S = Site Selection C = Construction R = Reg. approvals

*Details disclosed/available

Small-Mid Scale LNG Liquefaction Faciliies in the US*

Map Key Name Location LNG production Stage

1 Noble Energy Weld County, Colorado 100,000 gal/day P

2 APNG Topock LNG Plant Arizona 86,000 gal/day E

3 Clean Energy California Plant Boron, California 160,000 gal/day O

4 The Pickens Plant Willis, Texas 100,000 gal/day O

5 Shell, Geismar Geismar, Louisiana 250,000 P

6 Shell, Sarnia Sarnia, Ontario 250,000 P

7 Stabilis Energy Eagle Ford Shale 100,000/250,000 R8 Stabilis Energy West Texas 100,000/250,000 S

9 Stabilis Energy The Bakken 100,000/250,000 S

10 Stabilis Energy Western Oklahoma 100,000/250,000 S

11 Stabilis Energy Haynesville, East Texas 100,000/250,000 S

12 Grande Prairie Elmworth, Canada 190,000 litres/day C

13 Colony Energy Partners Reno 180,000 gal/day (initial) P

14 Spectrum LNG Prudhoe Bay, Alaska 100,000 gal/day P

15 Spectrum LNG Ehrenberg, Arizona 60,000 gal/day O

16 Exxon LaBarge Shute Creek, WY 60,000 gal/day O

17 Prometheus Bowerman LFG to LNG California 5,000 gal/day O


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1.6 Conclusion

Natural gas has significant potential to displace dieseland gasoline usage in the transportation sector. NGprices are both cheaper than either diesel or gasoline,and are also less volatile. NG is largely sourced inNorth America, especially the U.S., in contrast to oiland diesel, which are largely foreign-sourced, frompolitically unstable and potentially hostile regions ofthe world, especially the Middle East.

The number of CNG and LNG public access fuellingstations is expanding rapidly. Several companieshave committed themselves to rolling out new NGinfrastructure. On the CNG side, Trillium and LoveTravel Stops have announced extensive plans, whileon the LNG side, Shell, and ENN in a joint venturewith Blu LNG, are major players. Clean Energy has alsoannounced an extensive LNG plan, Americas NaturalGas Highway, and in partnership with Pilot Flying Jtruck stops is also exploring LCNG options.


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Chapter 2: Government policies: How they will

shape the NGV market over the next 5 years

2.0 Introduction

Government policies, at both federal and statelevels, have played a significant role in fostering thedevelopment of NG as a transportation fuel. Thefollowing chapter describes how such policies will

continue to shape the future development of the NGVsector, focusing on the next five years. The chapterbegins by discussing various state and federal policiesto promote NGVs, including subsidies, tax incentives,procurement policies, and emissions standards. Thechapter concludes by discussing two potential policyrisk factors that could thwart or at minimum slowdevelopment of NGVsenvironmental regulation,and export policy.

2.1 Policy in context

The DoE in 1993 launched the Clean Cities initiative,the flagship federal program designed to reducepetroleum consumption for transportation usesby promoting the use of alternative fuel vehicles.This program created a national network of morethan 100 Clean Cities coalitions, which link fuelsuppliers, private companies, original equipmentmanufacturers (OEMs), federal and state agencies,national laboratories, and local governments, amongothers, in designing and implementing alternativetransportation policies for their local communities.Clean Cities seeks to reduce the use of fossil fuels bymeasures such as using alternative and renewablefuels, making improvements in fuel economy, andpromoting emerging transportation technologies.

2.2 Subsidies and tax incentives

The significant and sustained lower relative cost ofNG compared to petroleum-based fuels provides a

strong incentive for fleets and individuals to shift toNGVs. Yet those who seek to make such a switch facetwo significant obstacles: the higher upfront cost ofNGVs, whether automobiles, vans, or light, medium,

or heavy-duty trucks, compared to diesel or gasoline-powered vehicles; and the lack of a comprehensivefuelling infrastructure for either CNG or LNG vehicles.

Both the federal government and many stategovernments provide a plethora of subsidies, taxincentives, and loan programs to address these twoobstacles (some of these incentive programmesare discussed more fully belowsee sections 3.__and 3.__, and 4.__ and 4.__). These public policiespromote the use of NGVs (and other alternative fuelvehicles) by defraying their higher upfront costsand also support build-out of more NG fuellingstations. Other policies provide incentives to usealternative fuel vehiclessuch as the ability to use

high occupancy vehicle (HOV) lanes regardless of thenumber of passengers in a vehicle.

Most of the NG-specific policies the United States

has in place promote the use of NG. But one federal

excise tax policy currently disadvantages LNG,

and this measure has attracted many reform calls

among various NGV stakeholders. The federal

excise tax on both LNG and diesel is currently 24.3

cents per gallon, but since it takes 1.7 gallons of

LNG to produce the same amount of energy that

a gallon of diesel produces, LNG is effectivelytaxed at a rate 70% higher than that of diesel.

Both gasoline and CNG are also taxed according to

energy output, leaving LNG as the odd fuel out.

Taxing the fuels on an energy content basis ratherthan on a volume basis would create a level playingfield for LNG, and Mac Thornberry, a member of theUnited States House of Representatives from Texas in2013 introduced the LNG Excise Tax Equalization Actof 2013 (H.R.2202), to achieve that goal. Thornberry

believes that this reform would promote expandedprivate-sector investment in LNG infrastructure andproduction.


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Senator Michael Bennet of Colorado has introduceda companion bill, S. 1103, l into the United States

Senate, but as of October 2013, the measures hadbeen referred to their respective committees forconsideration, and no further action has been takenon these measures.

The federal government currently has twenty-sevenNG promotion policies in place, covering a rangeof areas, including infrastructural development,HOV lane use, aftermarket conversions, publictransportation, and technological development.The DoEs AFDC regularly updated website provides

current summaries of existing federal policies: http://www.afdc.energy.gov/laws/laws/US/tech/3253

All states currently have at least one NG promotionpolicy in place, and the DoEs AFDC website allowsto search current such policies by fuel, and bystate. Many urban states are strong NG supporters,including California (with 27 NG policies in place),Virginia (16), and Indiana (18). States that produceNG also promote its use, these include Colorado (11),

Oklahoma (14) Texas (15), and Utah ( 10).http://www.afdc.energy.gov/laws/matrix/tech.

Policies fall to three broad areas: those that offsetthe incremental costs of NGV purchase; those thatprovide fuel incentives; and those that providespecial privileges to NGV users (e.g., access to HOVlanes, additional parking, concessions on emissionsinspections).

California has led the way in promoting clean air

policies, and adopted its Air Pollution ControlAct in 1947nearly a decade before the federal

government began to address air quality issues.

The state has been at the forefront of promoting

the use of alternative fuels, and currently has 27

NG state incentives in placemore than any other

state and these include policies to promote

NGVs, to encourage NG infrastructural

development, to advance the use of NG for public

transit, and to foster NG-related technological

development.

The DoEs AFDC website summarises the statescurrent policies http://www.afdc.energy.gov/laws/laws/CA/tech/3253

California has pioneered some innovative alternativefuel promotion policies, including parking incentives,

and the ability to use HOV lanes regardless ofthe number of passengers in a vehicle. Drivers ofqualifying alternative fuel vehiclesincluding CNG,hydrogen, electric, and plug-in hybrids-- that meetspecified state and federal emissions standards aregiven special stickers. Vehicles are also exempted fromcertain toll charges, unless prohibited by federal law.

On September 28 Governor Jerry Brown signedinto law a bill that will extend various other cleanvehicle incentive programs until 2023. He also signed

another piece of legislation that will extend for HOVlane access for certain alternative fuels vehicles untilJanuary 1, 2019.

2.3 Procurement policy

Both federal and state governments can advance theuse of NGVs via the procurement policies they enact.

Federal policy

President Obama issued a Presidential Memorandumin May 2011 directing all federal agencies to purchaseor lease only alternative fuel passenger vehicles or LDtrucks by 2015. This policy required no congressionalaction to be implemented and took immediateeffect upon announcement. Mandating the use ofalternative fuel vehicles for federal fleets was expectedto have the direct effect of stimulating demand forsuch vehicles and, by creating economies of scale,reducing the upfront costs of such vehicles, thusincreasing their attractiveness to a wider market.

Further, in the case of NGVs, placing more of themon the road was also intended to increase utilizationof existing NG infrastructure, and promote demandfor additional fuelling stations. The policy was alsoexpected to have indirect effects, as drivers of thesevehicles will increase their familiarity with thesevehicles and, in the case of NGVs, become aware oftheir far lower fuelling cost compared to petroleum-fuelled vehicles.

State policyStates have followed the federal lead in developingtheir own NGV procurement policies. The governorsof Colorado, Wyoming, Pennsylvania, and Oklahoma


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announced a Memorandum of Understanding (MOU)in November 2011 to work together to convert their

state vehicle fleets to NG. The MOU calls for a joint,multistate request for proposal for purchasing NGsfor state fleets, and commits each state to purchase aspecific number of NGVs. Many state fleets standingalone are not large enough convince OEMs that thevehicle needs of individual states represent a viable,stable, long-term market upon which to base productlaunch decisions. By developing a common proposalfor NGV purchases and pooling their resources, thestates hope to encourage OEMs to offer a wider rangeof NGVs. More than 20 states are now committed to

follow this NGV sourcing approach.

These procurement policies have already influencedproduct offerings. The three major U.S.-headquarteredOEMs Chrysler, Ford, and GM (Chevrolet) haveall launched bi-fuel pickup trucks, and GM and Fordoffer a bi-fuel van for commercial and fleet customers.Honda is the first OEM to offer a NG-fuelledautomobile, the Civic NG, nationwide to non-fleetcustomers, and Chevrolet intends to offer its Impala

model in a bi-fuel option for model year 2015. Variousother companies offer competitive NG-conversionoptions.

Private initiatives

These public procurement initiatives have inspired theAmerican Clean Skies Foundation to develop a widerprocurement plan for the third-party transportationservices used by the federal government. Every year,federal agencies spend roughly $150 billion on suchtransportation services.

The foundation has proposed requiring federalagencies to apply to third-party transportationproviders the same kinds of alternative fuel targets,efficiency standards and reporting practices theycurrently apply to their own vehicle fleets. Such apolicy would reduce overall oil consumptionandits associated economic and environmental costs.The foundation estimates that the programme itoutlined in an August 2012 report could deliverapproximately $7 billion in annual cost savings; cutpetroleum consumption by billions of gallons eachyear; stimulate the introduction of tens of thousandsof new alternatively fuelled vehicles; and reduce

greenhouse gas emissions by over 20 million metrictons annually. Moreover, the foundation emphasizes

that by leveraging its influence with freight carriersand other suppliers, such a programme would allowthe federal government an opportunity to create verylarge multiplier effects, and thus effectively reducethe dependence of the trucking industry and otherprivate sector transportation providers on petroleumimports.

2.4 CAF standards

The United States in 1975 first implementedCorporate Average Fuel Economy (CAF standards)to encourage manufacturers to produce more fuel-efficient cars. The Obama administration and thirteenOEMs on August 28, 2012 announced new standardsfor automobiles, and light and medium duty trucks,levelling the playing field between NG and otheralternative fuels for these categories of vehicles.These standards cover model years 2017-2025. Thestandards are ambitious ones, which by settingan average fuel economy standard of 54.5 miles

per gallon (MPG) by 2025double the 27.3 MPG2011 average-- are intended to push OEMs towardtechnological innovation. The standards include taxincentives for purchase of certain types of alternativefuel vehicles, and an incentive multiplier to encourageadoption of fuel. The highest multiplier, 2.0, applies toelectric vehicles; NGVs and hybrids enjoy a multiplierof 1.6a significant improvement on the previousstandard.

The Obama administration was the first to launch

emissions standards for heavy-duty vehicles in 2011.These are due to be revised and extended soon, witha proposed rule expected imminently, which will befinalized sometime in 2015.


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2.5 Environmental regulation:potential risk?

One potential risk factor for broader NGV developmentis whether additional environmental restrictions willbe imposed on fracking operations. At the federallevel, the Bureau of Land Management sets drillingstandards for federal lands, and the EnvironmentalProtection Agency (EPA) has broad influence overfracking due to its authority to set air and water qualitystandards. The EPA in 2012 set air quality standards forfracking operations, requiring companies to capture

gases released in the processbut these measuresonly codified best industry practices. The EPA isexpected to announce fracking-related water qualitystandards in 2014, and is expected to take a similarapproach.

The fracking industry remains vulnerable to the riskof lawsuits, which are largely brought under state law.Landowners have targeted energy companies in manystates where fracking is widespread, in some cases, viaclass action lawsuits. But the United States Supreme

Court has in recent years made it much more difficultfor private plaintiffs to succeed in such lawsuits,especially, in class actions. So far, no company has losta fracking suit, and the barriers to prevailing in suchlitigation for alleged harms including groundwatercontamination, triggering of earthquakes, orenvironmental degradation, are formidable.The possibility exists that lawsuits or state-level policychanges could slow the spread of fracking in certainstates. Yet absent a major shift in the composition ofeither Congress or the Supreme Court, it is unlikelythat fracking lawsuits will impose major constraints onenergy producers nationwide.

2.6 Export policy: potentialrisk?

United States NG export policy could also havea significant impact on the development of NGas a transportation fuel. Until recently, NG fromdomestic sources was not traded widely outside

North America, and the United States did not exportsignificant quantities of NG. In fact, before the shalegas revolution began, plans were underway to allowimportation of substantial quantities of NG, and these

included proposals to develop the infrastructure toachieve this goal. Some of the NG export terminals

discussed below were originally intended to be importfacilities.

Now, as domestic NG reserves continue to bedeveloped, and the spread between NG and worldoil prices continues to be so wide, this situationhas reversed itself. Yet U.S. NG exports are subjectto a complex export regime, which requires federalgovernment approval of NG export facilities andinvolves separate permitting processes undertakenby the DoE and the Federal Energy Regulatory

Commission (FERC). To date, the DoE has approvedfour applications to permit export of U.S.-producedLNG have been approved, and more than twentyare pending. In 2011, the DoE approved CheniereEnergys Sabine Pass project, located on the SabineRiver in the Louisiana/Texas border, thus clearing theway for the first new LNG construction in forty years(this project had originally been planned as an importterminal). Final clearance for this project led to apause in consideration of other export applications.

During this period, two studies were undertaken thatexamined the expected impact of NG exports ondomestic prices, and in this interim period, NG exportswere authorized to countries with which the US hasfree trade agreements, such as Canada and Mexico-- both members of the North American Free TradeAgreement (NAFTA).

In 2013, the DoE has approved three projects forexport to non free-trade agreement destinations:Freeport LNGs in Quintana Island, Texas, in May; Lake

Charles LLCs in Lake Charles, Louisiana, in August; andDominion Resourcess Cove Point facility on MarylandsChesapeake Bay, in September. The DoE has seeminglyaccelerated its review process in response to politicaland company complaints about previous delays, andis currently reviewing expansion of Freeport LNGsterminal in Freeport, Texas; Sempra Energys proposedproject in Cameron, Louisiana; and Veresens JordanCove project in Coos Bay, Oregon.


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Table 4 LNG Export facilities approved

Company Location State Date

CheniereEnergy

Sabine Pass Louisiana/Texasborder

Apr 2012

Freeport LNG QuintanaIsland

Texas May 2013

Lake CharlesLLC

Lake Charles Louisiana Aug 2013

DominionResources

Cove Point(ChesapeakeBay)

Maryland Sep 2013

NG producers view exports as a way to earn higherprices than are available for NG in either the domesticU.S. or wider North American market. Yet significantLNG exports could distort the domestic supply/demand relationship, and thereby raise domestic NGprices. As long as NG is largely traded within NorthAmerica, prices remain insulated from the volatility(and outright manipulation) that occurs in the worldoil market.

The acceleration of export procedures is alreadyprovoking a backlash. Cove Points conditionalapproval to export up to 0.77 Bcf/d of NG raisesthe overall amount of permitted NG exports,breaching the export levels of 6 Bcf/d the lowexport scenario set forth in an earlier reportcommissioned by the DoE that examined the impactof NG exports on domestic prices and on which theagency relied in approving three previous LNG exportapplications.

Americas Energy Advantage (AEA), a coalitionof manufacturers and consumers, is working toreserve US NG to promote a US manufacturingrenaissance. AEA members include domestic-headquartered companies such as Alcoa, Celanese,Dow Chemical, Eastman, Huntsman, and Nucor, andtrade associations, such as the American Public GasAssociation (APGA). Its membership also includesfirms such as Incitec Pivot, a global explosives andfertilizer manufacturer based in Australia, that recentlybegan construction of an $850 million ammonia plantin Waggaman, Louisiana.

In September 2013, AEA filed a formal motionto intervene in the DOEs proceeding evaluating

Freeport LNGs export application for its Freeport,Texas terminal. This application, if authorized wouldraise the cumulative volume of authorized LNGexports to 8.31 Bcf/d.

AEA seeks to encourage the DoE to develop a moreformal rulemaking process based on current dataand assessments of the current supply and demandenvironment. AEA asserts that current LNG exportapplications are being granted based on guidelinesdeveloped for NG imports in the 1980s. AEAs motion

also alleges that the legal standards the DOE used toanalyse the public interest in two previous permittingapplications were not adequate, appropriate, orsustainable.

APGA and the Industrial Energy Consumers ofAmerica (IECA) are working toward developing aresponsible production policy, arguing that whileexporting NG might maximize the price domesticproducers receive for their product, it will reduce the

price advantage NG currently enjoys relative to refineddiesel or gasoline, and thus reduce the attractivenessof NG as a transportation fuel. If that occurs, theseorganizations emphasize, NGs full potential to reduceAmericas energy dependency will not be achieved.

The DOE may choose to undertake another pause inits permitting procedures, but this is unlikely to occurbefore year-end 2013, when new data should beavailable from the Energy Information Administrationspreliminary annual energy outlook for 2014.

A lively debate is raging on how Americas NGreserves should be deployedto maximize producerrevenues, or to support domestic manufacturingand encourage energy self-sufficiency. Opponents ofincreased NG exports emphasise that if all pendingexport applications were to be approved, half ofcurrent NG supply would be exported. Instead,they advocate building necessary infrastructure toconsume NG domestically, not only for transportationuses, but for power generation as well.


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2.8 Conclusion

Government policies, both federal and state, haveplayed a major role in promoting the development ofNG as a transportation fuel, and will continue to do soboth in the near-term ad over the coming decades.

California has been a leader in developing alternativefuels, and currently has the most comprehensive NGfuelling infrastructure. While the state continues tolead the way in policy innovation, many other statesare also on the NG bandwagon, and are providingvarious incentives as well as setting their ownprocurement policies, to promote NG use.

Although it at this point appears unlikely thatenvironmental regulations or public or privatelawsuits, may significantly slow U.S. shale gasproduction, the long-term shape of U.S. NG exportpolicy is a cause for some concern, as it has thepotential to equalise somewhat domestic and worldNG prices, and thereby, reduce the economic case forfleets to switch to NG. A lively debate is brewing overwhether NG should be reserved for domestic uses,pitting conflicting interests of NG producers againstother among NG stakeholders. Since the setting ofexport policy requires federal government action, thisdebate will require political resolution at the highestlevel.


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Chapter 3: Converting to Natural Gas, Vehicle

issues

3.0 Introduction

Despite the relative cost advantage for fuelling NGVscompared to traditional diesel or gasoline-fuelledmodels, the higher relative costs of NGVs comparedto traditionally-fuelled vehicles has presented a majorobstacle to wider use of NG as a transportation fuel.This chapter focuses on costs and other issues thatshould be considered when contemplating switchingto NGVs, while the next discusses the equallyimportant issue of ensuring access to adequatefuelling infrastructure.

OEMs have started to offer a wider range of NGoptions, from automobiles, to vansboth passengerand cargoand light and medium-duty truckoptions. Total sales have been modest but growing,

and each OEM has announced plans for expansionof NG product offerings in forthcoming model years.At least twenty-one states provide some form ofincentive for fleets to convert to light-duty CNGvehicles, in the form of grants or rebates, loans, statetax credits, or combinations of these policies.With OEMs now offering a wider range of NGVs, theimpact of these incentive policies may now be morepronounced.All major heavy-duty truck manufacturers offer NG

options, either in CNG or LNG formats.

3.1 Passenger automobiles

The US market lags significantly behind the Europeanmarket in the number of NG options offered aspassenger vehicles. Currently, only Honda offersa CNG option, the Civic NG, nationwide in the US,compared to Europe, where many automakers,including Fiat, GM, Mercedes, Peugeot, Toyota and

Volkswagen, offer CNG options. Honda is stronglycommitted to develop the US NGV market and hasoffered a CNG automobile option since 1998 in theUS.

Chevrolet announced in October 2013 that it willlaunch a bi-fuel Impala, beginning with the 2015model year, to both passenger and fleet customers.The vehicle will include both a CNG tank in the trunk,and a gasoline tank, allowing for a total range of up to500 miles by switching between the two fuels-- 150miles on CNG and 350 miles on gasoline. GM hasneither announced an expected price, nor projectedfuel economy figures, and expects to sell as many as1000 vehicles, largely to fleets, during its first modelyear.

Despite a lack of strong consumer demand, OEMsrecognize that shifting to NG provides immediateemissions benefits, without any need for further

technological innovation, and thus help fulfil theirobligations to meet emissions standards for theirproduct offerings.

Two major obstacles have prevented wider consumeradoption of NGVs. Although the costs of operatingCNG vehicles are much lower, consumers must firstpay the higher incremental cost of buying a CNGvehicle. The actual break-even point depends onthe higher incremental cost for the CNG vehicle, andaverage number of miles driven. Moreover, passenger

cars face greater infrastructural obstacles, for unlikefleets, they do not necessarily drive in consistent andfamiliar patterns, and they lack access to dedicatedfuelling arrangementseither company-owned, orthird-party that are available to fleets.

Use of NG is impractical, at present, for non-fleetpassenger vehicles, outside of states that have well-developed CNG infrastructure, such as California, NewYork, Oklahoma, Texas, and Utah. In the near-term,

there are other pockets where use of such vehiclesmight catch on, especially in bi-fuel options, whichcan reduce fuelling and range anxiety.


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One looming technological innovation mightpromote popularity of NG as a transportation fuel

for passenger vehicles: the development of a cheap,widely available home refuelling option. At present,consumers are making a switch in how they viewfuelling options. Outside of remote rural areas,drivers are not accustomed to considering refuellingpossibilities when they drive passenger cars. But this ischanging, with the hybrids such as Toyotas Prius andChevrolets Volt.

Wider use of such vehicles may promote a shift inhow drivers think about fuelling their cars.

Electric vehicles have limited range, and are generallymost useful for commuting short distances.Drivers are able to charge their batteries when thevehicle returns home.

The lack of a cost-effective home fuelling applianceis seen as a major impediment to the development

of the NGV passenger automobile market, one whichthe federal government has devoted part of $30

million in research funds to finance proposals tocreate such appliances. The Drive Natural Gas Initiative(DNGI), a major industry trade association launchedits Home Fueling Appliance Task Force determinespecifications for such a product. The applianceshould be able to provide a fuelling rate of 1 GGEper hour, should provide for 6,000 hours of service,and should cost less than $1,500. This translates to afuelling cost per GGE of CNG of $0.25 (in addition withthe cost of the fuel itself and the cost of the electricityto run the compressor). The task force decided that

the cost of the appliance, plus the premium paid forthe CNG vehicle (compared to the same non-CNGmodel), must payout in 3 years or less, in order tosupport a sustainable market. Several utilities, andmanufacturers, are joining to develop products thatmeet these specifications. The timeframe for launchremains at least eighteen months away.

Table 5 Home fuelling specifications

Source: Americas Natural Gas Alliance

3.2 Light and medium duty trucking vehicle options

The major OEMs have responded to demand forCNG-fuelled vehicles, and either now offer, or plan tooffer for model year 2014, a mix of vans, and light andheavy duty pick-up trucks.

Ford

Ford expects to sell 15,000 CNG/LPG-prepped vehiclesin 2013, representing a 25% increase on its 2012 sales

of similar vehicles. Beginning with model year 2014,Ford intends to extend its product range and offerits F-150 truck with a gaseous-fuel prep option onthe 3.7-liter V6 engine, enabling the vehicle to run on

CNG or LPG. This prep package includes hardenedvalves, valve seats, pistons and rings so it can operateon either CNG/LPG or gasoline through separate fuelsystems, and from the factory costs approximately

TCOBase Case Miles % CNG NGV Cost HFA Cost High-Miles /

High CNG %

Actual miles 13,476 26,583 18,719

Daily miles 37 73 51

CNG percent 55% 106% 80%

NGV Premium $4,000 723 -$1,277

HFA (installed) $2,000

Simple Payout (yrs) 8.0 3.0 3.0 3.0 3.0 3.0

Market of 10 million

commuters


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$315 before the customer chooses a Ford QualifiedVehicle Modifier to supply fuel tanks, fuel lines and

unique fuel injectors. Upfits run approximately $7,500to $9,500, depending on fuel tank capacity.So equipped, F-150s would be able to run more than750 miles on one tank of gas, depending on the tanksize selected. The Ford F-150 averages 23 mpg on thehighway. Ford expects that CNG versions of the F-150will qualify for California HOV lane status certification,thus providing its commercial customers with asignificant time advantage, in addition to the costsavings they can expect to achieve on fuel.With the addition of the F-150, Ford will have eight

commercial vehicles available to run on CNG/LPG.

Table 6 Ford CNG model options (as of model

year 2014)

Model Type

F-150 Light-duty pick up

Transit Connect van and wagon

Transit van, wagon, cutaway, andstripped chassis

E-Series van, wagon, cutaway, andstripped chassis

F-Series Super Duty pick-up

F350 chassis cab

F-Series Super Duty (F-450,F-550)

chassis cab

F-650 medium-duty truck

F53 and F59 stripped chassis

Source: Ford September 19, 2013 press releaseChrysler

Chrysler launched the Ram 2500 CNG pick-up in2012 and sold its first vehicles in 2013. This is a bi-fuel vehicle that uses CNG as its primary fuel source,but automatically switches to gasoline when theCNG tanks are emptied. Using its two CNG tanks, thevehicles range exceeds 250 miles, and its back-upgasoline tank extends this range to nearly 370miles. The Ram 2500 is available to fleet and retailcustomers, and is powered by a Hemi 5.7 liter V8engine.

Of the three major US OEMs, Chrysler offers thesmallest range of CNG products, offering a pick-uponly for model year 2014.

Table 7 Chrysler CNG model options (as of model

year 2014)

Model Type

Dodge Ram 2500 Bi-fuel pick up

Source: Chrysler March 6, 2013 press release

GM

In 2013, GMC introduced its bi-fuel CNG Silverado2500 HD extended cab pick-up truck (the equivalentChevrolet model is called the Sierra 2500 HD), andexpects to sell 1300 of these vehicles during the 2013model year. The vehicle incorporates factory-installed

hardened exhaust valves and intake/exhaust valveseats, both of which are engineered to GM durabilitystandards for gaseous fuel use.The bi-fuel CNG option is available on long- orstandard-bed models in either 2WD or 4WD. The fuelsystem automatically switches to gasoline when theCNG tank is empty, or the driver may manually switchbetween fuel sources while driving. The combined 17GGE CNG tank and 36-gallon gasoline tank allow for atotal range of about 650 miles.

GMC and Chevrolet expect to offer a range of severaltruck and cargo van options for the 2014 model year.Chevrolet has also announced plans to offer its Impalaautomobile in a CNG configuration (see section 3.1above.)

Table 8 GMC and Chevrolet CNG model options

(as of model year 2014)

Model Type

Bi-Fuel CNG Chevrolet Silverado2500HD extended cab

pick-up

Bi-Fuel CNG GMC Sierra 2500HDextended cab

pick-up

Chevrolet Express 3500 cut-away

GMC Savana 3500 cut-away

Chevrolet Express Cargo 2500 cargo van

GMC Savana Cargo 2500 cargo van

Chevrolet Express Cutaway 4500 cut-away

Chevrolet Express Cargo 2500 cargo van

Source: GM website http://www.gmfleet.com/vehicle-overviews/fuel-efficiency/bi-fuel.html


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Payback: Bottom line

Assessing the conditions under which switching to

NG may be a commercially viable strategy for lightand medium-duty LGVs relies on a careful assessmentof over what timespan the additional premium forpurchasing differential vehicle can be recoupedby the cost savings for CNG fuelwhich currentlyaverage between $1.50 and $2 per DGE or GGE (asdiscussed more fully in section 1.1 above).

Leaving aside access to fuelling infrastructurewhichwill be discussed more fully in chapter 4 belowafleet operator must consider how many miles can

be driven fuelled by CNG alone, since most OEM bi-fuel options actually are currently configured with amuch higher gasoline capacity compared to CNG. Ingeneral, payback calculations are a less certain valueproposition, since vehicles in these classes alreadyhave higher fuel economy, and travel fewer models.

Figure 16 Calculation of light-duty truck payback,

based on various fuel price and truck premium

assumptions

Source: Paul Armstrong, GTI Director of Business Development,to Guild of Gas Managers, April 3, 2012.

Many states offer significant incentives in switchingto CNG, but these vary widely among states, and

many of them are time-bound. These factors may tipthe balance toward CNG significantly beyond whatmarket factors alone would dictate.

3.3 State subsidies for light-duty NGVS

As of September 2013, 27 states offer some formof incentives for converting fleets to light-dutyNGVs, according to VNG.CO, a company that offers anationwide CNG retail-centric fuelling facility programto owners and operators of light-duty NGVs. Thirteenstates offer grants or rebates, eight states offer taxcredits, and six offer loan financing at concessionaryrates. Several states offer various combinations ofthese incentives.

Table 9 Summary of state incentives for light-

duty CNG vehicles

Type of Incentive Number ofstates

Description

Grants or rebates 13 $2500 to $25,000 pervehicle

Loans 6 Rates from 0% to 5%

State tax credits 8 $500 to $7500 pervehicle

Source: VNG.CO website

$16,000$0.00

$1.00

$2.00

$3.00

$4.00

$5.00

$6.00

$7.00

$8.00

$9.00

$10.00

$8,000 $0

12,000 miles per yr - 3 yr Payback





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Figure 17 Map of states offering various incentives for light-duty CNG vehicles

Tax Credit

Rebate/Grant

Loan

Arkansas Up to $5,000 (


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3.4 Heavy duty trucking

Fleets operating heavy-duty trucks now have theoption to consider both CNG or LNG options. Allmajor truck manufacturers currently offer NG engineoptions, including Freightliner, Isuzu, Kenworth,Navistar, Peterbilt, and Volvo/Mack. These are basedaround engines offered & manufactured by WestportInnovations, in a 15 liter LNG option only, and in ajoint venture between Westport and Cummins, inboth CNG and LNG versions, and 8.9 liter and 11.9 litersizes. Volvo has announced plans to launch its own 13liter LNG engine sometime in 2015.

Technological innovation should over the longer termreduce these premiums. Manufacturers are currentlydeveloping new tank designs for both CNG and LNG.Additionally, innovations in the fuel system space--which accounts for the majority of the premium,should reduce overall truck premiums as well.

Some idea of the current premium for heavy dutyCNG or LNG rigs can be derived from Table 10, which

compares a CNG truck equipped with saddle tankswith 90 DGE of storage capacity to a single tank LNGtruck with 75 DGE of storage capacity. All of thesefigures are provisional, and are highly dependenton the relationships between suppliers and fleetmanagers.

Table 10 Heavy-Duty engine options

Manufacturer Model CNG engineprice

premium

LNG engineprice

premiumCummins/Westport

ISL G 8.9 L $32,000-$40,000

$35,000-$58,000

Cummins/Westport

ISX G 11.9 L $47,000-$80,000

$60,000-$98,000

WestportInnovations

HPDI 15 L LNG optiononly

$75,000-$120,000

Source: Loves Travel Stops, August 3, 2013 presentation

Figure 18 Natural gas engine comparison-- power(hp)

250

CWI ISL G CWI ISX12 G Westport 15L

375 400 475 500

Source: http://www.westport.com/products/engines/15

Figure 19 Natural gas engine comparison

torque (ft-lb)

600

CWI ISL G CWI ISX12 G Westport 15L

1,000 1,4001,200 1,600 1,800

Source: http://www.westport.com/products/engines/15

CNG to LNG compared

For heavy-duty trucks, both CNG and LNG options areavailable, and fleets looking to switch must carefullyconsider which option better suits their needs. CNG

trucks are heavierdue largely to tank design, andLNG has fuel-economy advantages in long-haulsituations. The additional weight required for its tanksdisadvantages CNG, but since 75% of heavy-dutytrucks cube out before they weigh out, this is notnecessarily dispositive, particularly given the currentlymore extensive CNG filling station network. (Seesection 4.2 below, and especially Table 12, for morediscussion of these considerations.)


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3.5 Factors to consider in HDeet conversions

Assuming access to adequate fuelling infrastructure,without the need to construct or secure access toa private fuelling network, many calculations ofexpected payback on conversion from diesel to eitherCNG or LNG rely only on the average differential infuel pricecurrently about $2 for CNG, and $1 forLNG. Yet there are other inefficiencies necessaryto consider when running heavy-duty trucks, andthese should be quantified on a per unit basis anddeducting the sum of inefficiencies from the grossdiscount.

LNG Filling issues

LNG may vent fuel into the atmosphere to avoidexplosion in a vacuum tank, and it may have a shelflife as short as four days. Filling completely emptymethane tanks can be problematic, as methanemay expand rapidly as LNG enters a tank at ambienttemperature, sometimes delaying operations by up toone day until a complete fill can be achieved.

Dealing with low temperature LNG raises some safetyconcerns; dealing with these imposes certain trainingcosts and also raises possible workers compensationconcerns.

Figure 20 Sample calculation of expected

payback for HD fleet conversion

CNG vs. LNG Comparison CNG LNG

Diesel Price $4.000 $4.000

Natural Gas Retail Price $2.000 $3.000

Gross Discount to Diesel $2.000 $1.000

Truck Inefficiencies

Fuel Economy Loss (12%) -0.240 -0.360

Out of Route Miles -0.025 -0.025

Payload Loss -0.050 -0.020

Additional Maintenance -0.030 -0.030

Fuel Loss from Venting - -0.015Salvage Value Deduction -0.060 -0.060

Total Inefficiencies -0.405 -0.510

Net Discount to Diesel $1.595 $0.490

Truck Comparison CNG LNG

Miles Driven (Annual) 125,000 125,000

Fuel Economy 6.20 6.20

Fuel Consumption 20,161 20,161

Truck Premium (CW 11.9L) 60,000 60,000

Net Discount to Diesel $1.60 $0.49Fuel Savings (Annual) $32,157 $9,879

Payback (Years) 1.87 6.07


Range considerations

Onboard fuel capacity dictates the range for bothCNG and LNG trucks. Standard CNG fuel systemscome equipped with the option of either 90 DGEsaddle tanks or 120 DGE behind-the-cab tanks. Only

about 90% of this capacity is considered usable,since a CNG truck also experiences a shortfall whenfilling at rates higher than ten DGEs per minute.Although fuel is not lost, the rapid fuelling producesheat which expands the hydrocarbons, thus takingup more space, and resulting in a capacity loss ofapproximately 5%, leaving total range for a CNGvehicle with saddle tanks at about 450 miles ofrange.


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Figure 21 Sample CNG range calculation

90 DGE Storage Capacity (9 DGE Unusable + 4.5 DGE Heat Expansion)=76.5 DGE Useable Capacity

76.5 DGE Useable Capacity * 6 Miles Per GallonFuel Economy = 459 Miles of Range


CNG fuel systems are currently available with up to150 DGE capacity that yield over 750 miles of range.

LNG has a fuel system design which allows a truck touse one hundred 100% of all fuel capacity, usually 75DGE for a single tank or one 150 DGE for dual saddletanks. Using the same fuel economy calculations as forCNG above, LNG vehicles can achieve a range of up to900 miles.

Truck Weight

The additional weight differential for an NGV truck isoften overstated since it considers only the additionalweight of needed storage tanks and mountingbrackets, without subtracting the weight of parallelcomponents required by diesel trucks, or the weightadvantage of CNG itself compared to an equivalentenergy output of diesel. An aluminium diesel tankwith mounting kit can weigh between 100 and 200pounds. Also, depending on API gravity, diesel fuel

can weigh between 6.95 and 7.05 pounds per gallonversus a natural gas DGE at 6.50 pounds per gallon,giving NG a weight advantage of .50 pounds pergallon. Neither do spark ignited NG engines requireSCR systems or a DEF tank.

Table 11 Weight diesel truck compared to CNG

truck and LNG truck (full tanks in lbs)

CNG 80 DGE LNG 75 DGE

NG tank weight 1600 1200

Less

Diesel tank weight (75gallon)

665 665

SCR System and DEFweight

458 458

Net additional NG weight 477 77


* Note, however, that trucks that use HPDI technology,such as the Westport 15 Liter Engine, are compressionignited and require an SCR system under currentemissions standards.

Payback: Bottom Line

When all these factors are carefully considered--and once again, emphasising that all necessarycosts for any infrastructural construction are left tochapter 4 to discuss, payback for fleet conversion,

assuming 125,000 miles driven annually, can be fewerthan 2 years for CNG vehicles using a Cummins/Westport 11.9 liter engine, and just over 6 yearsfor an equivalent LNG rig. These calculations donot consider possible state subsidies, which aresummarised in the next section.

The preceding analysis is based on calculations doneby Loves Travel Stores, but others have made similarcalculationson slightly different assumptions.


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Figure 23 Heavy-duty incentives, Canada and US (as of August 2013)

New Existing

BRITISH COLUMBIA

FORTIS Natural Gas for Transport(NGT) Incentive Program for LNG

Covers up to 70% of incremental

LNG only:HD Class 8 (11,793kg+) MD Vocational (incl. waste,transit, marine)

FORTIS Light Duty VehicleIncentive Program

Bi-fuel WiNG 250-550 eligible upto $10,000 per vehicle

No close date

COLORADO

Alternative Fuel Income Tax Credit

35% tax creditcapped at $6,000for vehicles under 26,000lbs

CNG and bi-fuel

Until 2016

CALIFORNIA

SJVAD Drive Clean RebateProgram

Rebate up to $3,000

BAF products on eligibility list

Ongoing

TEXASH-GAC Clean Vehicles GrantProgram

$20 - $40,000 for HD

CNG/ LNG/ bi-fuel

Open until funds exhaust

QUEBEC

Accelerated Capital CostAllowance

60% depreciation forLNG trucks

WEST VIRGINIA

AFV Tax credit of 35%

$7500 < 26,000lbs

$25,000 > 26,000lbs

Dedicated or bi fuelCNG/LNG

OKLAHOMA

One-time income taxcredit for 50% of theincremental costs

Until Sept. 10, 2013

NORTH CAROLINA

Reimbursementprogram, up to 80% ofincremental costs

Until Sept. 10, 2013

LOUISIANA

Income tax credit up to50% of the incrementalcost up to $3,000

Dedicated CNG/LNGonly

ARKANSAS

50% rebates for CNGand LNG conversions,up to $4500

Source: http://www.cumminswestport.com/pdfs/general/Aug%20-%20Sept%202013%20NA%20On-Road%20Incentives.pdf

3.7 Conclusion

Manufacturers have stepped up their offerings ofNGVs, across vehicle classes, especially in the heavy-duty truck sector, where customers are responding tothe potential significant fuel costs savings.The value proposition for passenger cars is lesscertain, outside certain regions already well-servedby adequate fuelling infrastructure, in the absenceof a home refuelling option. In the light-duty sector,the value proposition is also at present somewhat

ambiguous, but should improve, once technologicalimprovements and economies of scale drive thepremiums for NGVs downward. At the moment, manyof the NGVs on offer are not fully configured by theOEM, but involce conversion elements. Costs shouldfall when OEMs commit to fully configuring NGVSthemselves, rather than relying on outsourcing andconversions.


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Chapter 4: Building Dedicated Fuelling

Infrastructure, CNG and LNG

4.1 Introduction

Infrastructural considerations continue to loom largein decisions to convert all or part of a fleets vehiclesto NGV, and with the increasing availability of varioustypes of NGVs, are the largest consideration in fleet

conversion decisions. Although more infrastructure,both CNG and LNG, is continually coming on-line,as described in (sections 1.3 and 1.4 above), atpresent, fleets located in most regions with theexception of California, New York, Oklahoma, Texas,and Utah

Documents

NGV Industry Overview Report v9X