Letter to Penny Pritzker, Secretary of the Department of Commerce - Labeling of Liquefied Natural Gas

Letter

Dear Secretary Pritzker:

Next week, the National Conference on Weights and Measures (NCWM) plans to vote on a steering committee recommendation to permit retailers of Compressed Natural Gas (CNG) and Liquefied Natural Gas (LNG) to sell these fuels in diesel gallon equivalent (DGE) units. While the NCWM is an independent entity, it works closely with the Commerce Department's National Institute of Standards and Technology (NIST), which has expressed reservations about the proposal. NIST would reportedly prefer to have CNG and LNG sold in units of mass, specifically kilograms.

We appreciate the technical expertise of NIST, but we think the NCWM's special Natural Gas Steering Committee struck the right balance in March of this year when it endorsed a plan to measure natural gas by mass but permit marketing of CNG and LNG in DGE units when sold as motor fuel. As explained by the steering committee's chairman, the proposal "allows consumers [to] compare cost and quantity and allows equipment manufacturers to design systems to meet just one set of requirements."

This proposal is consistent with and maintains the United States' nearly twenty-year history of marketing CNG in gasoline gallon equivalent (GGE) units. The proposal also has the support of many in industry, including companies engaged in the production and delivery of natural gas, and organizations promoting the use of natural gas-powered vehicles.

There is growing interest in the use of cleaner, U.S. produced vehicle fuels, and we believe the NCWM steering committee's recommendation will encourage even greater consumer adoption. The value of the proposal for consumers, even those who have not yet purchased a natural gas vehicle, is underscored by the U.S. Government's own reports on alternative fuels. For example, the quarterly Clean Cities Alternative Fuel Price Report issued by the Department of Energy compares the prices of various fuels, including CNG, in both GGE and DGE units. The April 2014 report also notes that consumer interest in alternative fuels generally increases when the cost savings "per gallon" increase. Without marketing of CNG and LNG in gallon equivalents, such price comparisons will be unrealistically difficult for consumers--or potential consumers--to make.

For these reasons, we support the proposal endorsed by the NCWM steering committee and ask that you encourage NIST to work closely with the natural gas industry and other key stakeholders to find common ground for a process and a standard that will benefit all parties.

Thank you for your consideration of this important matter.

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