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Comments to the CARB Draft Proposed Concept – CNG Motor Vehicle Specifications

Comments to the CARB Draft Proposed Concept – CNG Motor Vehicle Specifications. Tony Estrada CAT Senior Program Manager PG&E August 3, 2005. Introduction. PG&E supports CARB’s objectives in providing compliance flexibility in meeting the CNG motor vehicle specifications while ensuring:

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Comments to the CARB Draft Proposed Concept – CNG Motor Vehicle Specifications

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  1. Comments to the CARB Draft Proposed Concept – CNG Motor Vehicle Specifications Tony Estrada CAT Senior Program Manager PG&E August 3, 2005

  2. Introduction • PG&E supports CARB’s objectives in providing compliance flexibility in meeting the CNG motor vehicle specifications while ensuring: • Existing & new technology engines are protected • No significant degradation in air quality occurs. • PG&E supports the concept that the current CNG motor vehicle specifications have to move away from prescriptive gas compositional standards and instead address motor vehicle performance & emission standards. • PG&E believes that the CPUC should be the primary lead agency in regulating natural gas quality specifications.

  3. Comments-Performance & Compositional Specifications • CARB proposal of statewide minimum MN 80 specification • PG&E agrees with this proposal. • CARB proposal of a regional minimum MN 73 specification • PG&E agrees with this proposal. • CARB proposal of “TBD” Wobbe Index specification • PG&E recommends that the CARB CNG spec not include a Wobbe Index spec since this appliance-related item is being addressed in the CPUC gas quality proceedings.

  4. Comments-Performance & Compositional Specifications (cont’d) • CARB proposal of max C4+ specification of 1.5 % • PG&E recommends removing this specification since the MN specification already includes the impact of the heavy hydrocarbons in the fuel’s MN calculation. • Otherwise, this somewhat redundant spec defeats the purpose of the MN spec. • CARB proposal of max inerts specification of 4 % • PG&E recommends removing this specification since it is being addressed in the CPUC gas quality proceedings. • Otherwise, the need for this spec needs to be substantiated.

  5. Additional Comments • PG&E supports the concept of granting a statewide CNG vehicle fuel spec exemptions to: • Light Duty CNG vehicles • CNG Residential Fueling Appliances • PG&E supports research & additional testing to provide the technical basis for CARB specifications.

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