The purpose of this letter is to urge you to support the establishment of a national standard for dispensing CNG and LNG in diesel gallon equivalent units.  Standards adopted by the National Conference of Weights and Measures (NCWM) in 1994 require CNG to be sold in gasoline gallon equivalents (GGE).  That standard has benefited consumers and industry alike because it provides a common unit for comparing the average energy in CNG to the average energy in a gasoline gallon.  It also provides a ready means of informing consumers as to the relative economic cost of natural gas compared to gasoline.  All of the retail pumps used today in the U.S. use the GGE unit for dispensing CNG and all retail stations price CNG in GGE units.  Moreover, many states increasingly are using the GGE as the most appropriate unit for taxing CNG.

The natural gas industry has requested that NCWM adopt a diesel gallon equivalent unit for CNG and LNG that is sold to truckers and other users who typically use diesel fuel.  From the purchaser’s perspective, the pump display and readings would show the number of DGE units dispensed and information would be provided on the pump to show how natural gas is converted to DGE units.  We think that this is the only rational way to offer CNG and LNG when sold to truck operators.  Under the proposal, LNG would only be sold in DGE units since LNG is expected to be used exclusively as a heavy-duty vehicle fuel.  CNG would be dispensed in GGE units at retail outlets serving the general public and would be sold in DGE units on pumps selling to trucks and heavy-duty vehicles.

The need for this action is driven by the fact that there currently is significant national interest in promoting increased use of natural gas in heavy-duty vehicles where diesel fuel has traditionally been used.  The federal government and many state governments currently have in place policies intended to expand the use of natural gas as a transportation fuel.  Private firms are investing hundreds of millions of dollars establishing a national network of retail fueling stations to supply this fuel to motor vehicles.  Development of a weights and measures standard for a diesel gallon equivalent of natural gas will complement the effort made 20 years ago to create the GGE standard.

NCWM is currently considering this issue and may vote on it later this summer.  A number of key state weights and measures officials do not support adoption of a DGE unit or the continued use of the GGE unit as the primary methods of selling natural gas.  Instead, these officials support a proposal to require that natural gas be sold in kilograms — despite the fact that there is no industry support for such a standard and no fueling stations currently sell natural gas in kilograms in the U.S.  These state officials say that all fuels should be dispensed in metric units but currently only plan to require this for natural gas.  This proposal is not only discriminatory but will put natural gas at a significant disadvantage to other fuels by creating confusion for consumers who are not used to purchasing motor fuel in mass units let alone kilograms.  This standard will increase the cost of new pumps and it will impose costly retrofit of existing pumps.

For all of these stated reasons, we support adoption of a national DGE standard for CNG and LNG and do not support the alternative approach that would require the use of mass (kilograms or pounds) as the primary unit for selling CNG and LNG. Having to sell in kilograms or pounds as a stand-alone unit or even a secondary unit will cause confusion, unnecessarily increase the cost of retailers providing this fuel to market, and create inequity among fuels.

Thank you in advance for your support.

Action:

1. Write to or contact your state weights and measure official(s) (see link below) to let them know that you support adoption of a DGE standard for CNG and LNG that provides for the use of this standard as the primary method of sale.  https://www.ncwm.net/resource/state-directors-all.

2. Write the NCWM NGV Steering Committee Chairman Mahesh Albuquerque and request that he provide a copy of your letter or email to the NGV Steering Committee members.  Tell him that you support adoption of a DGE standard for CNG and LNG that provides for the use of this standard as the primary method of sale.  Mahesh Albuquerque (mahesh.albuquerque@state.co.us).