Association Française du Gaz Naturel pour Véhicules
AFGNV
AFGNV brings together French public, economic and industrial players to support the development of natural gas and renewable gases used as fuel in France.
ID: 592721138745-06
Lobbying Activity
Response to Revision of Alternative Fuels Infrastructure Directive
18 Nov 2021
AFGNV welcomes the revision of the current Alternative Fuels Infrastructure Directive, which should align with the GHG emission reduction targets of the EU. AFGNV is convinced that the only way of achieving a quick decarbonisation of road transport is to support all existing solutions, including biomethane (both in compressed and liquified forms – bioCNG and bioLNG).
As recognised by the European Commission in the Impact Assessment of the AFIR proposal, “biogas and e-gases use the same refuelling infrastructure as natural gas. Fossil natural gas can therefore be increasingly blended and phased out with low-carbon and renewable fuels (…) and thus fully contribute to the climate-neutrality objective” (p.19).
The CNG and LNG refuelling station network is therefore a potent enabler for increasing the uptake of bioCNG/bioLNG and therefore of a drastic reduction in GHG emissions of road transport. Europe’s gas fuelling station network has reached 4 000 CNG and 400 LNG stations. This network is crucial to support the decarbonisation of transport, whether in the trucks, coaches, buses, vans or cars markets . Biomethane (bioCNG and bioLNG) already represents 20% of the gas used in the European vehicles fleet,.
All these elements should have been better taken into account in the European Commission’s proposal and related infrastructure targets. In order to ensure that the CNG and LNG refuelling stations are better supported across the EU, AFGNV has the following recommendations for improving the AFIR proposal:
• Create a coherent Fit-for-55 Package: the AFIR should not anticipate the results of the revisions of the CO2 standards for cars & vans as well as for heavy-duty vehicles by prematurely phasing-out support to CNG and LNG infrastructure. These legislations will define new targets for cutting GHG emissions of new vehicles, and it is therefore crucial that the AFIR matches these updated ambitions.
• Properly align with the existing legal framework; the AFIR should act in a coherent and complementary way with the Renewable Energy Directive, which already defines the types of fuels that should be produced and used to decarbonise road transport. The new sub-categories of alternative fuels introduced in the European Commission’s proposal are not based on any clear legal criteria and bring additional unnecessary complexity to the overall FF55 framework. Instead, the definition of “alternative fuels” within the AFIR should rather mirror the definitions of the REDII, and clearly include advanced biofuels such as bioCNG and bioLNG within its scope, since biomethane is recognized by REDII as an efficient energy for decarbonization
• Reintroduce provisions to support the development of CNG refuelling stations. While the number of CNG stations is growing steadily, distribution across Europe remains highly uneven. Development of CNG for coaches and buses is strongly increasing in several countries . CNG is an efficient solution to both decarbonize and preserve air quality for these vehicles that need significant autonomy and for which LNG is not available. Additional investments are therefore needed to build and maintain a comprehensive network of CNG refuelling stations that is necessary to increase the uptake of bioCNG in road transport.
• Extend the support to LNG refuelling stations beyond 2025. With a high blend of bioLNG achievable in the medium term, LNG is a mature, affordable and necessary technology to accelerate the decarbonisation of the long haul heavy-duty vehicles, since it is the only immediately viable alternative fuel to diesel for this specific sector. While the LNG stations is developing quickly, it still remains largely insufficient to match the growing demand for bioLNG and increasing numbers of LNG trucks in Europe. It is therefore crucial to extend the development of the LNG stations across the European Union beyond 2025.
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