OpenLobby.EU
Explore

NGVA Europe

NGVA Europe

NGVA Europe represents the industry for natural gas and biomethane vehicles in Europe.

Lobbying Activity

NGVA Europe demands level playing field for gaseous fuels

17 May 2023
Topic — The European Commission is reviewing CO2 emission standards for heavy-duty vehicles.
Message — The organization calls for a regulation that ensures a level playing field among all viable technologies. They state that accounting for the actual environmental footprint of the fuels is critical.12
Why — This regulatory approach would create the market conditions for expanding their fuel deployment.3
Read full response

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans) and FuelsEurope and

20 Dec 2022 · CO2 standards trucks and buses

Meeting with Ismail Ertug (Member of the European Parliament, Rapporteur) and E-GAP S.r.l. Società Benefit

5 Dec 2022 · AFIR

Meeting with Elzbieta Lukaniuk (Cabinet of Commissioner Adina Vălean), Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean)

9 Nov 2022 · Role of biomethane in CO2 standards for HDV

Meeting with Jens Gieseke (Member of the European Parliament, Shadow rapporteur)

16 Mar 2022 · Austausch zur EU-Umweltpolitik

Meeting with Jens Gieseke (Member of the European Parliament, Shadow rapporteur) and European Biodiesel Board and Liquid Gas Europe

9 Feb 2022 · Austausch zur EU-Verkehrspolitik

Response to Revision of the Energy Tax Directive

18 Nov 2021

NGVA Europe welcomes the revision of the Energy Taxation Directive, which should align with the increased GHG emission reduction targets of the EU. NGVA Europe 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). In order for the Energy Taxation Directive to become a truly effective instrument driving the decarbonisation of fuels used in road transport in a fair and cost-effective way, NGVA Europe has the following recommendations: • Welcomes the switch to an energy-based taxation for all fuels, which will create more transparency and readability for consumers. • Raises however strong concerns over the proposed levels of minimum tax rates for natural gas used as a fuel, which risk to jeopardize the future of the biogas market in road transport. Because gas used in vehicles is a blend, – currently over 20% of the gas used in the EU fleet is biomethane (bioCNG and bioLNG) – raising tax levels for natural gas to this proposed extend, and in such short time frame, would severely compromise the further development of biomethane, whose uptake rely on the competitive advantage of its fossil counter-part over conventional fuels. This would have counter-productive effects, since biomethane is one of the only already available alternative solutions to decarbonise road transport – especially for the heavy-duty sector. The increase of minimum tax levels should rather be proportionate to the potential of fossil fuels to integrate higher blends of renewables. • Setting minimum tax levels based on the environmental performance of the fuels is a good step in the right direction, but it should be consistently applied to all energy carriers, and not only to gaseous and liquid fuels. Minimum tax rates for electricity should also be set based on its environmental performance, which heavily depends on the origin of the energy used to produce it. On the same logic, natural gas used as a fuel should also benefit from lower minimum tax rates than petrol/gasoil as of 2023 and until after 2033, to reflect its positive effects in reducing GHG emissions compared to conventional fuels. • Give more flexibility to Member States to apply different nominal tax rates even below the minimum rate thresholds, in line with local resources and especially in accordance with their overall strategy for decarbonisation defined in their National Energy and Climate Plans. The possibilities for exemptions should also consider the level of market penetration specified per sector of application. • Ensure that the distinction of the different types of gaseous fuels to set the applicable minimum levels is done based on a reliable and robust tracking system. Gaseous fuels cannot be physically traced, as it is impossible to differentiate once in the pipeline between molecules of biomethane and fossil gas. A clear methodology is therefore necessary to avoid that, due to this physical constraint, biomethane is applied same minimum tax rates as natural gas, which would be in direct contradiction with the objectives of the ETD’s revision.
Read full response

Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

NGVA Europe welcomes the revision of the Renewable Energy Directive, which should align with the increased GHG emission reduction targets of the EU. For this reason, NGVA Europe supports the proposed increased targets for the transport sector combined with the deletion of multipliers for advanced biofuels and renewable electricity. Biomethane (bioCNG and bioLNG) are playing, and can continue to play, a key role in the increased use of low carbon fuels in transport, and meeting the higher ambition of the RED. NGVA Europe would like to express the following recommendations to improve the proposal of the European Commission: • Ensure that the extension of the Union Database to gaseous fuels is compatible with the gas market architecture and trading practices. In their current state, the proposed rules would create significant interpretation and applicability issues for gaseous fuels (both in gaseous or liquid forms, for biomethane), which represents a significant risk that those requirements will hinder the deployment of renewable gases in the future. The European Commission should reconsider the proposed implementing rules and the intention for them to cover gaseous fuels. At least, the European Commission should consider tailored rules for gaseous fuels which would fully acknowledge the specificity of their supply chains and markets. • Ensure that the proposed credit mechanism for renewable fuels supplied to the transport sector can benefit in a fair way to all fuel suppliers and apply to all fuels supported by the REDIII. RED needs to act in conjunction with other key policy elements, such as AFIR. It is essential that the AFIR continues to support the growth in bioCNG and bioLNG refuelling networks beyond 2025 in order for the ambition of the RED to be realised.
Read full response

Response to Revision of Alternative Fuels Infrastructure Directive

18 Nov 2021

NGVA Europe welcomes the revision of the current Alternative Fuels Infrastructure Directive, which should align with the increased GHG emission reduction targets of the EU. NGVA Europe 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). 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. Earlier this year, Europe’s gas fuelling station network has reached 4 000 CNG and 400 LNG stations. This network is crucial to support the decarbonisation of the 1,5 million gas vehicles which currently compose the European fleet, as well as the foreseen 13,2 million gas vehicles that NGVA Europe projects for 2030. Biomethane (bioCNG and bioLNG) already represents more than 20% of the gas used in the European vehicles fleet, which contributes to reduce GHG emissions by more than 40% compared to gasoline (on a Well-to-Wheel basis). The CNG and LNG refuelling network is not yet complete across the EU, and indeed there remain significant geographical gaps. In order to ensure that the full climate advantage of biomethane is realised across the EU, NGVA Europe has the following recommendations for improving the AFIR proposal (see document attached).
Read full response

Response to Revision of the CO2 emission standards for cars and vans

8 Nov 2021

NGVA Europe welcomes this opportunity to further comment on the proposal of the European Commission to revise the CO2 standards for cars & vans. Setting an ambitious 2035 target of a 100% reduction in GHG emissions solely based on tailpipe, without recognizing the potential of renewable fuels in cutting the emissions of road transport means a de facto ban of the internal combustion engine vehicles. The reduction of CO2 in transport requires to focus on decarbonisation of the fuels rather than on the underlying drive-train technology: an internal combustion engine (ICE), fuelled with renewable sustainable fuels such as biomethane, has a carbon footprint comparable to that of an electric vehicle or even less than that. While it is essential to drastically lower transport emissions, the proposal of the EC fails to allow the EU to enable climate neutrality for transport in a swift and socio-economically efficient manner. That is because this approach prevents the EU from reaping the great benefits yielded from additional CO2 savings stemming from renewable sustainable fuels such as biomethane, while failing to ensure that the transition towards carbon neutral mobility does not leave anyone behind. In doing so, the EU is at the same time contradicting its own principle of technology neutrality. The focus should be put instead on decarbonising the fuel, not banning the engine that uses it. The results of the EU stakeholder consultation on the revision of CO2 emissions standards for cars and vans demonstrate that a large number of respondents are in favour of a mechanism that takes into account the contribution of sustainable renewable fuels in the future CO2 fleet regulation. With more than 1,000 responses to the question: “A mechanism should be introduced in the CO2 emission standards for cars and vans so that compliance assessment for each manufacturer takes into account the contribution of renewable and low carbon fuels”, approximately 70% responded that this option is of “high importance”. In 2020, Frontier Economics proposed a voluntary crediting system that would allow automotive manufacturers (OEMs) to partially benefit from the use of sustainable renewable fuels for compliance with their targets (for the integrity of the system, Frontier Economics suggests capping the volumes of sustainable renewable fuels that OEMs can have credited against their fleet targets). Such a scheme received the support of 223 representatives from the fuel industry, associations, companies and scientists. NGVA Europe is therefore disappointed that the European Commission rejected the inclusion of such a scheme in the proposal for revising the CO2 standards regulation. NGVA Europe also finds the arguments developed in the Impact Assessment to justify this rejection unsatisfactory and insufficient. Another recent study from Frontier Economics – that will be published on the 09th of November 2021 – points at the gaps within the IA’s methodology, and demonstrates that: - Crediting is a valuable low-carbon option for the environment, consumers and manufacturers - A crediting system can be implemented at limited administrative cost - A voluntary crediting system is a “no regret” measure and a step towards a holistic, resilient and effective climate policy Against this background, NGVA Europe reiterates its call to include the crediting mechanism for renewable fuels within the revised CO2 emissions standards for cars & vans.
Read full response

Meeting with Adina-Ioana Vălean (Commissioner)

21 Jun 2021 · Meeting CEO

Meeting with Helena Hinto (Cabinet of Commissioner Kadri Simson), Laure Chapuis (Cabinet of Commissioner Kadri Simson) and

30 Apr 2021 · To discuss priorities in climate policy and carbon emission reduction in the mobility sector.

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean) and FuelsEurope and

23 Mar 2021 · Renewable fuels to climate neutrality and economic growth

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness) and European Biogas Association and Gas Distributors for Sustainability

8 Mar 2021 · EU taxonomy, draft delegated act

Meeting with Henrik Hololei (Director-General Mobility and Transport) and European Biogas Association and Gas Distributors for Sustainability

4 Mar 2021 · Sustainable and Smart Mobility Strategy

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and FuelsEurope and

1 Mar 2021 · European Green Deal

Response to Climate change mitigation and adaptation taxonomy

16 Dec 2020

NGVA Europe welcomes the publication of the draft delegated acts (DA) setting the first Technical Screening Criteria (TCS). NGVA Europe would like to express its recommendations for guaranteeing the consistency of the TCS across technologies, and ensure that the EU Taxonomy fulfils its objective, which is to accelerate green investments in all sustainable activities, including biogas-based mobility. GENERAL PRINCIPLES: • The TSC should refrain from setting double standards to safeguard predictability for investments Businesses, governments and financial actors should not be faced with double standards that could disrupt markets, distort competition and result in excessive costs. This is particularly important for the transport sector, where vehicles and fuels industries need a stable legislative framework to drive the necessary investments. The TSC should align with the existing EU legislation that has been specifically designed to decarbonise transport. It should not inconsistently cherry-pick EU standards, without a transparent rationale. This endangers the development of already available low emissions mobility solutions such as natural and renewable gas-based transport. • The TSC should support the entire value chains of sustainable activities In order to be a tool that truly incentivises sustainable investments, the Taxonomy should make sure to cover activities of entire sustainable value chains. In this perspective, NGVA Europe welcomes the integration of the “Manufacture of biogas and biofuels for use in transport” in the climate mitigation activities. However, this will not be effective if the missing link between the production and the consumption sides remains. Indeed, the TSC exclude all types of vehicles running on biomethane/biogas and associated refuelling infrastructure from the scope of climate change mitigation activities. This is also a missed opportunity to acknowledge the great contribution of biomethane to a transition to a circular economy. • The TSC should be based on a consistent methodology to include all available sustainable technologies As it stands, the TSC suffer from important inconsistencies and methodological flaws that prevent investors from making fully informed decisions on their investments. For instance, the absence of Life Cycle Analysis of the transport related activities does not provide with the real climate impact of all mobility solutions in terms of GHG emission reductions. This creates an uneven playing field where the so called “zero-emission” options are systematically considered as sustainable, independently from the origin of the fuel. Instead, the great potential of solutions like biomethane are not recognised (see documents attached). RECOMMENDATIONS: 1) The TSC related to climate change mitigation for activities linked to road transport (3.3, 6.3, 6.5, 6.6, 6.15) should align with the definition given in article 2 (34) and criteria of Annex IX, Part A of the RED II, in order to include biomethane used in transport. The REDII already provides with robust sustainability criteria to define which advanced biofuels to support in order to drive the decarbonisation of transport. Biomethane in transport qualifies as an “advanced biofuel” according to Annex IX, part A of REDII. Furthermore, according to Article 10 (1)(a) of the Taxonomy Regulation, activities generating, distributing or using renewable energy in line with RED II qualify as substantially contributing to climate change mitigation. This includes biomethane in transport. 2) The TSC for activities 6.3 and 6.6 should also align with standards already set in article 4 (4)(b) of the Clean Vehicles Directive to define what is a “clean heavy-duty vehicle”. 3) Delete the labelling of “transitional” for activity 4.13. The manufacture of biogas and biofuels for transport allow for “producing clean and efficient fuels from renewable or carbon-neutral sources”, as specified in article 10(1) of Regulation 2020/852.
Read full response

Response to Revision of the CO2 emission standards for cars and vans

26 Nov 2020

The publication of the 2030 Climate Plan by the European Commission increased the overall GHG emissions reduction target for 2030 from -40% up to -55% (vs 1990 level). The long-term reduction goal for 2050 remains unchanged, but the new plan asks for an acceleration across multiple sectors in the next decade. This acceleration will be also reflected in the revision of the CO2 emissions standard for cars&vans regulation (2019/631). NGVA considers this represents the timely opportunity to introduce a new paradigm in the regulation structure. Today, this regulation misses the technology neutrality principle due to the measurement of tailpipe emissions only. If fighting climate change phenomena is the objective, CO2 tailpipe emissions represent only a part of the reality, ignoring the critical contribution that sustainable biofuels can provide to that. Consequently, today a battery electric vehicle powered with the current EU electricity mix relies on close to 50% contribution from fossil energy sources, but nevertheless is considered “zero” emissions. On the other hand, a vehicle fuelled with bioCNG is considered fully fossil, despite providing in some cases even a negative GHG emissions balance. This is the result of an obsolete regulation, that has been developed at the time when the market was entirely based on thermal engines and conventional/alternative fossil fuels. In light of this, some specific considerations: A) The risk not to include the fuel dimension in the CO2 average OEMs’ fleet calculation Maintaining a silos approach between fuels and mobility legislation (i.e. RED II/FQD from one side and CO2 emissions standard regulation on the other one) is not and will not stimulate the vehicle industry to further invest in cost-effective and available solutions like CNG/LNG that, thanks to biomethane, can concretely contribute towards the decarbonization of the mobility sector needed to reach climate neutrality by 2050. Instead of accelerating the process of decarbonisation, whose taking off is particularly crucial in the next decade, the huge investments needed to support the switch towards electrification might take decade before reaching a critical level. Breaking those silos is necessary to fill the gap, and make sure that Europe will be able to achieve its environmental targets. Moreover, by betting on a single solution, Europe risks to rapidly lose competitiveness and jobs in one of the sectors where we are recognized as worldwide leaders. B) The need for the revision of the CO2 emissions standard regulation Despite being a valid scientific argument, we recognise the difficulty of introducing a full Well-to-Wheel approach in this revision of the regulation. Nevertheless, a complementary legislative tool (methodology) is needed to recognise the climate benefit linked to bio and synthetic fuel, as already mentioned in art.15 of the 2019/631 regulation. The CO2 credit generated by the sustainable renewable fuel consumed by the vehicle should be available to OEMs to demonstrate that investments in certain technologies, such as CNG and LNG dedicated vehicles, are contributing beyond the simple tailpipe benefit. This acknowledgement must lead to a “net-zero” emission vehicle labelling, equivalent to the current “zero” level recognized only to full electric solutions. It is also important to recall the cross sectorial role that renewable fuels, such as biomethane, can play in creating a virtuous circle between agricultural and waste sectors, energy production and storage, and its use in transport. This revision can create the long-awaited conditions to further invest in easy mobility technologies that can bring enormous benefits to our environment and our society.
Read full response

Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

To reduce CO2 emissions in transport in the next decade, we need to leverage the solutions that are available today. This is especially true in view of an EGD increase of climate ambition. The pressure to deliver requires solutions that could be implemented at a low investments cost. The use of biomethane in transport meets all these conditions. Its production matches EU's need for both an economic recovery and a green transition generating local jobs while tackling CO2 emissions across several sectors, especially transport. Natural gas technology is ready to provide a fast and strong contribution to the challenge of decarbonization. In 2019, several countries devoted considerable shares of renewable gas in transport, namely Iceland (100%), Norway (100%), Sweden (94%), the Netherlands (90%), UK (80%), and Finland (59%), making carbon neutrality in transport already a reality. In terms of bio-LNG production and use, there are already examples of applications in France, Italy, the Netherlands, Sweden, and Norway. We see the gradual reduction in CO2 intensity of fuels put on the market in combination with stimulus for carmakers to use such fuel as one of the most cost-effective solutions for carbon abatement. This would translate into the continuation of the Fuel Quality Directive targets which ensures the fuel with the best environmental performance to be placed on the market. At the same time, a recognition of the fuel production dimension within the CO2 standards regulations for mobility is needed. Producing biomethane offers the opportunity to convert our waste into clean fuel for our vehicles. Methane is a greenhouse gas emitted in the atmosphere from the natural decomposition of organic materials (municipal waste, sewage or food waste). Producing biomethane means to capture it, providing economic value to green energy production. With the same chemical composition of natural gas, biomethane and can be injected into the natural gas distribution grids or used directly by vehicles. At this end, more feedstock should be included in the Annex IX part A of RED II, recognizing the potential of multiple renewable gases available, including power-to-gas. We believe Annex IX should be revised to broaden the scope of eligible biowaste according to the definition in the Waste Directive (2018/851). A category for intermediary crops (including catch crops, cover crops) should also be created in the list as they provide numerous environmental benefits. For example, as long as there is no impact on the food production chain and no additional land use (neither direct nor indirect) when farmers introduce an additional second harvest for energy purposes, they should have the possibility to innovate into secondary crops for energy use. Southern regions are fit for the production of high yield cover crops, and R&D is ongoing, innovating on more types of fast-growing high yield cover crops. In addition, renewable gas can also originate from wind and solar power which, thanks to the Power-to-Gas technology, is transformed for the exceeding volumes into sustainable and storable fuel. An increasing amount of renewable gas is already available and fully in line with the strictest sustainability criteria set by European legislation. However, the legislation in place provides support to produce renewable fuels, but there is no mechanism to stimulate consumption, and eventually releasing such production from the public support dependency by creating a demand-based market. For this reason, the potential revision of the REDII should be conducted in parallel with the CO2 emissions standard regulation for vehicles to create an effective system where both dimensions can contribute to transport decarbonization in a synergic way. This concept is partially expressed by option 3 and 4 from the inception impact assessment.
Read full response

Response to Sustainable and Smart Mobility Strategy

29 Jul 2020

NGVA Europe shares the concerns of the EU Commission about the rising levels of GHG emissions of the transport sector. The pandemic crisis demonstrated the paramount importance of a resilient road transport system. The post-pandemic period is therefore the opportunity to accelerate the transition towards net-zero emissions mobility by making the most of already available clean technologies such as natural & renewable gas mobility, while embarking all consumers in a speedy economic recovery. The next Smart and Sustainable Mobility Strategy should be designed according to the following principles: Leverage on available solutions to accelerate the decarbonisation. This means accelerating the production of renewable fuels such as biomethane, able to have a climate-positive impact already on the existing fleet. Incentives for the deployment of refuelling infrastructure (including small scale LNG infrastructures and for new/retrofitted gas vehicles) and EU R&I programmes must be planned accordingly, supporting all low emissions mobility enabling technologies. System affordability is key to avoid a two-speed Europe towards clean mobility, aggravating the gap between Eastern and Western Europe. The rolling out of EVs and FCEVs can be costly for consumers and the energy system. Natural gas together with renewable gas, being based on conventional technologies and an already structured distribution network, is the most cost-efficient way to penetrate the market and contribute to the decarbonization process. An interoperable, multimodal transport system for goods and passengers. This should be the result of the most efficient and sustainable combination between waterborne, road and railway. In this context, CNG and LNG are already today a pivotal component of the EU’s transport system. Besides their application in the road sector, they can synergistically be exploited for maritime and rail mobility. The interoperability among refuelling stations, bunkering operations, and digital connection with productions plants would made the use of this versatile fuel even more efficient. Include the fuel dimension in the revision of the CO2 emissions standard regulation. Leveraging on the CO2 emissions reduction only at tailpipe level is not sufficient to ensure the shift in 2030-2040 to a more carbon neutral mobility. Without the contribution of renewable fuels, the CO2 emissions from the EU fleet will not be reduced at lifecycle level. They must be part of the future CO2 emissions standard regulation to stimulate vehicle manufacturers to continue producing also in the future highly efficient engines compatible with those fuels. Natural gas mobility can strongly contribute to the issues highlighted above. Biomethane and synthetic gas are renewable energy sources with very low carbon footprints, and a GHG reduction potential of up to 95%. When produced from liquid manure, it prevents the release of methane happening in nature, yet even negative emissions are possible. This enables a gas vehicle to operate as carbon neutral. Renewable gas is already broadly available for consumers across Europe. Currently, a share of 17% of gas used as fuel within the transport sector is renewable (bioCNG and bioLNG). In 2030, this share is estimated to rise up to 40%, with a correspondent CO2 emissions reduction of more than 55% compared to convention fuels. Natural gas mobility has a key role to play in ensuring clean mobility that is affordable to all. Any share of renewable gas can be blended in, which allows low GDP Member States to actively support the energy transition. Moreover, gas allows for a fuel cost saving of 30% compared with diesel and up to 50% compared with gasoline. Policy actions are therefore needed through: Incentives for the construction of gas refuelling stations, small scale LNG infrastructures and for new/retrofitted gas vehicles Tax exemptions for (bio)LNG and (bio)CNG, reflecting their positive externalities to environment and human health
Read full response

Response to Development of Euro 7 emission standards for cars, vans, lorries and buses

2 Jun 2020

NGVA Europe's feedback is available on the attached document.
Read full response

Response to Revision of Alternative Fuels Infrastructure Directive

4 May 2020

The AFID is of great importance since it sets reference targets for Member states as an indication of a given density of infrastructure that should be achieved. In this regard, the AFID has been fundamental in the development of the CNG and LNG market. Financial incentives have helped to improve the number of refuelling points, especially in Western Europe. This form of incentive needs to be continued for the progression of natural gas infrastructure deployment into Eastern Europe. For the decarbonisation of the transport sector it is important to have an aligned Europe. To continue this successful pattern, the revision of the Alternative Fuels Infrastructure should follow the following principles: 1. Consistency across pieces of legislation – It is important to keep consistency with related pieces of legislation to ensure the most cost-effective outcome. To facilitate a homogeneous market throughout Europe, consistency must be ensured across the different regulations supporting zero and low emission vehicles as well as alternative gases and fuels and EU projects putting in place such measures at the national levels. Consistency is even more necessary until the introduction of a more comprehensive approach for assessing the environmental benefits from mobility solutions, especially considering the role that renewable fuels can play in decarbonising transport emissions. Only a Well-to-Wheel approach can guarantee a fair and complete assessment of the decarbonisation effect among different solutions, translating the need to ensure technology neutrality. Looking only at the long-term vision and narrowing down decarbonisation solutions risks to seriously endanger market dynamics. In particular, the affordability of ready-to-go options should not be forgotten when assessing an overall mobility system transformation. 2. Recognition of the neutrality of the infrastructures - Infrastructures are an enabler for the decarbonisation process, therefore must be considered neutral. The continuous inclusion of alternative fuels would enable a progressive transition of the transportation system, ensuring affordability and at the same time good environmental performance. The fact that for biomethane we cannot distinguish between molecules of fossil origin and renewable origin, cannot represent a discriminatory criterion to exclude natural gas from the scope of the Directive. Otherwise, the same criteria should apply to electricity and hydrogen. In fact, we follow this approach, we should also distinguish between electric grids distributing coal-based electricity and based on renewable energy sources. De facto, no infrastructures should be incentivized anymore. On the contrary, progressive incorporation of renewables in both grids and pipelines will ensure the highest carbon reduction. 3. Higher decarbonisation targets require more decarbonisation tool - It is extremely important to consider that the infrastructure developed and to be developed for CNG and LNG, as well as the vehicle technologies and the well-spread gas infrastructures, do not need any intervention for using renewable gas (biomethane and/or synthetic). It is a system that, without any additional cost, guarantees flexibility across Member States to support the progressive utilization of renewable gas in a cost-efficient way. This means to create a tangible circular economy model, where the transport sector can get benefit from the conversion of waste biomasses coming from the agri-food and waste sector. In the transport sector specifically, some gas suppliers are already offering 100% renewable gas, and an increasing number of fleet operators are committed to switching to 100% renewable gas fuelled transport. Such initiatives should be recognised and encouraged by appropriate legislative tools in order to become mainstream
Read full response

Response to Revision of the Energy Tax Directive

1 Apr 2020

NGVA Europe represents an industry that is fully committed to the objectives of the Green Deal. In this perspective, NGVA Europe stresses that clean fuels - such as natural and renewable gas – are essential solutions to decarbonise transports and to reach the emissions reduction targets. Renewable gas, especially biomethane, has a prominent role to play since fully compatible with current natural gas technologies, meaning that it can be blended at every ratio and directly used on vehicles or injected in the grid. Hence, NGVA Europe formulates a series of recommendations for the revision of the Energy Taxation Directive. These recommendations aim at better supporting alternative fuels to steer their environmental benefits and to ensure consistency among the ETD and other EU climate policy objectives. NGVA Europe suggests the followings: •The ETD should allow to apply a preferential taxation level linked to the contribution towards a low emissions mobility. This would guarantee the promotion of the clean alternative fuels, and therefore better coherence with the Alternative Fuels Infrastructure Directive (DAFI). It would also boost the promotion of the most performing renewable and low emissions energies. •The level of taxation should also consider the level of market penetration specified per sector of application (and not limited to heating) in order to promote alternative fuels. This will ensure consistency with other pieces of European legislation, specifically with the Alternative Fuels Infrastructure Directive. •The ETD must maintain a level playing field with regards all type of fuels. If minimum taxation rate should apply to all fossil fuels, then the same principle should equally find application for electricity, without discrimination about its use in different sectors. In other terms, minimum level of taxation should equally be introduced for this type of energy in the annex dedicated to its usage as a motor fuel, rather than only in the annex addressing the heating use (Annex I, table C). •The review of sectoral tax differentiation is required to meet EU climate objectives. At the moment, only gas oil can get a differentiated tax rate depending on the private or commercial usage (article 7 §2). For the sake of consistency, this option should be extended to all fuels listed under the AFI Directive. Likewise, all public transport passengers and not only local public transport passengers should benefit of a differentiated taxation rate (article 5) to drive the uptake of alternative fuels.
Read full response

Response to Climate Law

6 Feb 2020

NGVA Europe, ahead of the publication of the Climate Law, recommends the followings in the assessment of a potential increase of CO2 reduction ambition: • More ambition requires more solutions The new European Green Deal calls for a 90% reduction in transport emissions by 2050. Road transport cannot be decarbonised fast enough to get the EU on track to climate neutrality by 2050 without transition options, such as biofuels and natural gas. Gas application is the bridge for higher electrification of mobility and at the same time qualifies as a long-term solution. Electrification alone won’t solve the challenge we are facing when we consider the whole system. CNG, LNG along with renewable gases are effective solutions. The competitiveness of battery-electric solutions is challenging against LNG because a lot of payload and passenger capacity are lost because due to the battery's size and weight. Decarbonising the transport system is a long-term process, which is further complicated by cars being individual property with high purchase costs, and because there are big differences among national car fleets. Most of those cars are several years old and not fit for a zero-emission mobility system. A mechanism to support the renewal of the current EU fleet is therefore needed. Moreover, H2 will offer solutions for a few niche market applications, while Europe needs viable and critical options today. It is also important to address the consumer needs and to support those technologies not only environmentally, but also socially sustainable. • The definition of carbon neutrality needs to be clarified Climate neutrality vs net zero-emissions: An activity or a product – like a car or a fuel – is climate-neutral when you can demonstrate that the overall CO2 emissions from the entire life cycle standpoint are zero. Fortunately, this is not the only way to reduce emissions and reach carbon neutrality. Some processes offset CO2 emissions. We can then achieve net-zero emissions when any GHG emissions are balanced out by removing an equivalent amount of carbon from the atmosphere. An excellent example is the production of biomethane. It converts our waste into clean fuel for vehicles. The methane that would be emitted into the atmosphere from the natural decomposition of organic materials (municipal waste, sewage, or food waste) is instead captured, granting economic value to green energy production. By doing so, the carbon removal equals the emissions of the same amount of fuel used in a car. For some pathways - e.g. liquid manure - the final offset value is even negative. Reduction of CO2 emissions needs to happen across the whole value chain: An LCA footprint represents an interesting, yet essential indicator to assess the total CO2 emissions associated with certain vehicle technology. When considering our target to decarbonise the transport system, this is the right angle to approach the needed analysis. In fact, GHG emissions need to be considered on a global scale and as the result of a sum of contributions. Today’s solutions based on conventional technologies have a better manufacturing footprint than newer solutions like electric vehicles. When considering the use of renewable gas, no matter which is its origin, the overall footprint of a natural gas vehicle is very competitive. • Retain competitiveness in Europe and avoiding market distortion The way EU policies are made should aim at clearly setting out the conditions for an effective and fair transition. When outlining the long-term direction, they have to provide predictability for investors and other economic actors, including employers, workers, and consumers, to ensure that the transition to climate neutrality is irreversible. Forcing the EU consumers to buy non-EU technologies is already proving to be climate-wise ineffective, resulting in cheaper and more polluting alternatives - like conventional fuels - be chosen.
Read full response

Response to A new Circular Economy Action Plan

20 Jan 2020

Renewable gas production is a clever approach to manage waste and residues from households and the agriculture sector. These materials would have otherwise been disposed, and the consequent emissions released in the atmosphere. Producing biomethane offers instead the opportunity to convert our waste into clean fuel for vehicles. Methane is a potent greenhouse gas (GHG) emitted in the atmosphere from the natural decomposition of organic materials (municipal waste, sewage or food waste). Producing biomethane means to capture it, providing economic value to green energy production. Renewable gas is an advanced biofuel and makes a major contribution to climate objectives. Biomethane and synthetic gas are renewable energy sources with a very low carbon footprint and a GHG reduction potential of up to 95%. When applied as fuels, they allow gas vehicles to run carbon neutral. This progressive integration will find further application in the mobility sector, where combustion engines will be able to welcome a higher share of renewable gas combined with green hydrogen-based fuels. While producing sustainable energy, high-quality by-products, such as bio-fertiliser, are generated. A really good example of circular economy, targeting emissions in agriculture and waste, that still needs a full legislative recognition. While putting in place the future European Circular Economy strategy, more consistency across existing European legislation must be guaranteed. The value of biogas, biomethane and renewable gaseous fuels and related by-product and by-uses needs to be improved to maximize the value generated by all the single steps of the value chain. Agricultural, Renewable Energy, Mobility and Chemical policies are today too fragmented to complete the circularity of the resources use. A practical example would be the introduction of a Well-to-Wheel solution to set a bridge between the production of renewable gas and consumption in the transport sector. When renewable fuels burn, they generate CO2 emissions, but carbon in the fuel is the result of the natural CO2 capture and conversion during the lifetime of the raw material used to produce the fuel. That is why renewable fuels generate a CO2 credit and, when burning, the CO2 emissions are totally compensated (closed CO2 cycle). NGVA Europe strongly supports the parallel development of an Industrial Strategy for Europe. This is essential to keep ensuring leadership in high-skilled engineering jobs for both energy production (anaerobic digesters and electrolysers) and efficient combustion engines for cars, trucks, and ships. At the same time, renewable gas production through material recycling is most of the time locally generated. That means giving a further option for income to EU jobs and economic growth also in rural, farming areas.
Read full response

Response to Evaluation of the Alternative Fuels Infrastructure Directive

20 Mar 2019

The Alternative Fuels Infrastructure Directive should keep on recognizing the technological neutrality of the infrastructures. The inclusion of CNG and LNG in the definition of alternative fuels should be maintained as relevant part of the EU’s decarbonisation goal. The progressive incorporation of renewable gases is able to make CO2 emissions dropping significantly for both current and future fleets. The continuous inclusion of these fuels would enable a progressive transition of the transportation system, ensuring affordability and at the same time good environmental performance. It is important to keep consistency with related pieces of legislation to ensure the most cost-effective outcome. To facilitate a homogeneous market throughout Europe, consistency must be ensured across the different regulations supporting zero and low emission vehicles as well as alternative gases and fuels and EU projects putting in place such measures at the national levels. This will guarantee interoperability among European countries since CNG and LNG in the transport sector are already a reality with high availability, flexibility and scalability potential. The consistency is even more necessary until the introduction of a more comprehensive approach for assessing the environmental benefits from the mobility solutions, especially considering the role that renewable fuels can play in decarbonising transport emissions. Only a Well-to-Wheel approach can guarantee a fair and complete assessment of the decarbonisation effect among different solutions, translating the need to ensure technology neutrality. Looking only at the long-term vision and narrowing down decarbonisation solutions risks to seriously endanger market dynamics. In particular, affordability of ready-to-go options should not be forgotten when assessing an overall mobility system transformation. It is in fact not possible to predict how quickly the electricity network of infrastructure (from transmission down to domestic recharging) will adapt to the increase of demand. The CNG and LNG infrastructures serve today to both private and professional users. The vehicles running on natural gas are used for different ‘mission profiles’ or, in other words, there are passenger cars, buses, vans and trucks to cover all types of road transport in Europe. Apart from its main use in road transport, natural gas has started becoming an ever more interesting solution in maritime application where heavy-fuel oils are replaced by clean fuels such as LNG. Support for CNG and LNG is no regret as the infrastructure and vehicle engines can use biomethane as soon as available.
Read full response

Response to Urban Mobility in the EU

17 Dec 2018

Here below the feedback about the Urban Mobility in the EU Strategy: - From an industrial standpoint, it is fundamental to guarantee product competitiveness. The local conditions will drive the deployment of matching fuels and powertrain technologies, asking for a multiplication of solutions and calling for a technology neutrality approach. - Considering the life span of a vehicle, the environmental footprint of the existing vehicle fleet should be tackled today to deliver immediate benefits in terms of decarbonisation and air quality. - Achieving better local air quality, especially in the highly populated urban agglomerations, should be prioritised and be in line with European regulation. Local measures should not ban certain technologies from the urban area, but rather considering local pollutants emissions level. - Consistency across the different policies is needed, along with a coordinated effort of all the measures and funded projects to ensure from one side the profitability of the investments, and on the other side an effective delivery of expected environmental benefits. - A system approach towards urban mobility investment should be taken into account when transforming such a complex field that is urban mobility. This includes affordability of technology, costs of energy, distribution of energy infrastructure. In other terms, an acknowledgement of the life cycle costs. - A European Joint Undertaking should be established to promote the deployment of renewable gas in transport, from biomethane to synthetic gas. This includes production to the end use. Renewable gas in transport is going to play a significant role in the decarbonization of urban mobility. - The TEN-T program limits its scope to the core transport network (mainly high-way) while not considering as a binding criterion the population density and consequently the vehicles density, lacking investments to place necessary CNG (Compressed Natural Gas) stations in urban areas. - Zero and Low Emissions Vehicles areas should be defined according to criteria developed in the European regulation, guiding the European cities to define their restrictive measures.
Read full response

Response to Implementing act on a common methodology for alternative fuels unit price comparison

29 Mar 2018

NGVA Europe believes that an important factor for the successful market introduction and adaptation to alternative fuels is comprehensive and transparent consumer information. Understandable and comparable prices are fundamental to this. Currently, in the EU-28 different fuels are priced in different sales units without this being visible on the filling station totem. The energy content per sales unit varies greatly among different fuel options in some cases. Since both petrol and diesel fuels are charged as liquids in litres, over the last years pricing without unit specification has been established on the filling station totem. Both natural gas and biomethane are alternative fuels available that are charged per kilogram. Electricity is priced per kilowatt hour, and hydrogen per kilogram or per 100 grams. This makes it impractical to directly compare against liquid fossil fuels. It is, therefore, not possible to directly compare different fuel prices on the filling station totems. At the same time, the option to compare fuels based on € per 100 km driven is a respectable alternative method, however, the drawback is that this would be subject to the vehicle efficiency that would be dependent on different driving scenarios. As such, NGVA Europe recommends that the price indication as € per 100 km should rather be part of a commercial information package and should not displayed at the station. It is alternative fuels, such as natural and renewable gas that are expected to contribute towards reducing CO2 emissions from transport. At the same time, those alternative options are being indirectly penalized by the difference in pricing display, which currently does not provide an equal basis for comparison. This is important because consumers notice the pricing of all available fuels at the stations and a lower price would drive not only their purchasing decision, but also indirectly lowering CO2 emissions by switching to alternative fuels. The energy content principle would be the most transparent in this respect. In other words, the prices expressed in €/kWh or per €/10 kWh would be the best option and even more transparent than petrol litre equivalent. As such, NGVA Europe would support the position that all fuels, including the ones based on liters, i.e. petrol, diesel and LPG are included. Therefore, a future common methodology pricing should pursue the following objectives: • The price-performance ratio of different fuels must be made comparable (prices expressed in €/kWh), thus offering consumers the ability to make an informed decision • Alternative fuels, such as natural and renewable gas, should be made more visually attractive and should be supported in competitive markets • The energy tax credit for alternative fuels must be maximized through transparent pricing In summary, NGVA would opt for the energy content approach based on kWh as the best option, litre equivalent would be the second-best option. Any other methodology could be used for commercial purposes but should not be displayed at the stations.
Read full response

Response to Post 2020 light vehicle CO2 Regulation(s)

23 Mar 2018

The Natural Gas Vehicle Association (NGVA Europe) is a European association that promotes the use of natural and renewable gas as a fuel in vehicles and ships. Founded in 2008, its 135 members from 31 countries include companies and national associations from across the entire gas and vehicle manufacturing chain. NGVA Europe welcomes the publication of the EU Commission’s second part of the Mobility Package and stresses the importance to introduce a more comprehensive approach for assessing the environmental benefits from the mobility solutions. In this context, a well-to-wheel approach can guarantee a fair and complete evaluation of the decarbonization effect among different solutions, and it results as a fundamental booster to introduce more renewable energy sources in the transportation sector in a cost-effective way. Natural gas contains less carbon than traditional hydrocarbon fuels and, therefore, emits much less CO2 as a vehicle fuel. Because NGVs start with cleaner fuel and have a very clean combustion process, it is easier to guarantee good emissions performance during the lifetime of the vehicle. For passenger cars and light commercial vehicles, natural gas emissions are 7% lower than diesel and 23% lower than gasoline; for trucks and buses, the reductions are between 6% and 16% . Additionally, NGVs are much cleaner in terms of local pollutants such as particulates, sulphur oxides and nitrogen oxides. Therefore, supporting CO2 reduction potential via alternative and synthetic fuels in a technologically-neutral approach, NGVA Europe sees the need for: • a technology neutral overall approach towards ambitious but achievable targets o all alternative technologies, including both natural and renewable gas, should be recognized for their role in transport decarbonization that they achieve already today o the regulations should not indirectly prioritize or prescribe any single technologies through tailpipe CO2 evaluation • the currently-proposed tailpipe approach should take into account the GHG savings from renewable fuels, such as biomethane or synthetic gas and, therefore, must deduct this benefit in the monitoring and reporting phase o renewable gas already offers GHG savings of around 80% from municipal waste and up to 95% from synthetic gas o as such renewable gas should be prioritized in the legislations and natural gas vehicles should be classified as “Low to Zero emission vehicles” • a regulatory transition to a Well-to-Wheel methodology in the medium to long term should be supported and achieved • benefit from the second mobility package, but focus on the synergies between the different directives, i.e. Directive for Alternative Fuels Infrastructure, the proposal for CO2 regulation and the proposal for the definition of a clean vehicle o as such, the definition of clean vehicles should be harmonized with the approach taken in the Directive for Alternative Fuels Infrastructure, focusing on all alternative technologies listed, which is technology-neutral and not based on CO2 values
Read full response

Response to Heavy Duty Vehicles CO2 emission standards

18 Dec 2017

NGVA Europe welcomes the impact assessment on Heavy Duty Vehicles (HDV) CO2 emission standards and views it as an important step towards decarbonising heavy-duty transport and offering sustainable solutions that can reduce emissions and ensure the use of clean fuels and technologies. NGVA Europe believes that in any future scenario, transport solutions have to be designed with the customer in mind, while also considering the different vehicle mission profiles, the geographical conditions and, of course, the local market conditions. As well as the customer viewpoint, the requirements of the technology suppliers (Original Equipment Manufacturers) must be considered by offering viable manufacturing scalability of new technologies in order to achieve price and cost goals. Simultaneously, serving customer and OEM needs while delivering broad decarbonisation of the transport sector requires a strategic vision at global level coupled with local analysis in order to guarantee product competitiveness and define favourable conditions for investments. Clearly this approach would translate into multiple solutions, where different vehicle technologies best fit with fuels and energy under diverse operational and market demands. No single silver bullet solution exists that will, alone, lead to decarbonisation in the transport sector. Therefore, a range of sustainable options are going to be necessary and the use of natural gas represents one of the key and most effective solutions to fight climate change and improve air quality in a cost-efficient way, particularly in the transport sector. Both CNG (Compressed Natural Gas) and LNG (Liquefied Natural Gas) are viable and scalable solutions that can sustain efficiently a large variety of transportation modes with an immediate reduction on greenhouse gas (GHG) emissions and pollutants. Both CNG and LNG can also be produced from a variety of renewable energy sources, such as: organic waste and biomass produced through anaerobic digestion; gasification processes; or by directly converting carbon dioxide (CO2) into synthetic methane by using hydrogen produced from surplus electricity. Furthermore, because renewable gas is practically identical to natural gas, even moderate blend levels are able to enhance the beneficial effects of using natural gas substantially, which is already a low-carbon fuel and thus enabling significant reductions of the total GHG emissions. Considering the overall Well-to-Wheel (WtW) impact, there are significant benefits and reduced GHG emissions from passenger cars as well as light and heavy-duty vehicles when switching to CNG or LNG from petrol and diesel. In case a full WtW approach should not be considered at this stage, the role of renewable fuels, such as biomethane or synthetic gas should be acknowledged. As such, NGVA Europe proposes a CO2 Correction Factor (CCF) acting at monitoring phase level. The CCF will be function of the percentage of renewable gas certified by each Member State. This way, the type approval procedure is not affected and remains based on engine emissions and VECTO SW tool calculations. The CCF can also be also applied to vehicle fleets, whose use with a specific renewable gas rate can be directly certified by the car manufacturer. Taking this approach into account in the proposed regulation will ensure the success of the immediate benefit that natural and renewable gas can offer, and will give a clear signal to both manufacturers and gas industry to continue in the development of the necessary refuelling infrastructure, as proposed in the DAFI.
Read full response

Meeting with Bernd Biervert (Cabinet of Vice-President Maroš Šefčovič)

17 Oct 2017 · Mobility Package, Role of gas

Response to Evaluation Energy Taxation Directive

25 Sept 2017

NGVA Europe position on the process of evaluation of the Energy Taxation Directive NGVA Europe points out the crucial period the transportation sector is facing, especially in the last period after the Dieselgate, in developing environmentally friendly solutions that also rely on a wider use of clean alternative fuels such as natural gas. Decarbonisation and air quality issues being the fundamentals for the next years policy actions, natural gas provides a cost-effective solution for high efficient engines with low emissions even under real driving conditions; and renewable gas, on top of that, reveals as ideal way to a carbon neutral transportation system within a virtuous circular economy approach. Moreover, the natural gas grid represents a natural and accessible storage system to also recovery intermittent production of renewable electricity through synthetic gas production. Today gas industry stakeholders are concentrating the efforts in ensuring a faster development of CNG and LNG solutions, through the development of new clean vehicles and modern refuelling infrastructures, as well as of new standards to provide a wider interoperability of the system among Member States. Under this perspective it is also fundamental to consider the action plans that have been recently developed by Member States in response to the Directive on Alternative Fuels Infrastructure 2014/94/EC, and the consequent role of a complementary support from the Energy Taxation Directive. Several Member States have clearly adopted natural gas and renewable gas as key solution for a sustainable mobility and transport system and as effective way to also increase the use of renewable energies, creating adequate taxation conditions to accompany this development; such favourable taxation system is an absolute necessity for natural gas development to reach a critical mass in the market. For these reasons NGVA Europe recommends maintaining the conditions adopted for natural and renewable gas in the text of the current Energy Taxation Directive to ensure the economic stability and support the consequent industrial investment and market development uptake looking at least to the 2030 timeframe.
Read full response

Meeting with Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete)

25 Jul 2017 · Fuels and CO2 emission standards for buses, vans and trucks

Meeting with Friedrich-Nikolaus von Peter (Cabinet of Commissioner Violeta Bulc)

24 May 2017 · study presentation

Meeting with Violeta Bulc (Commissioner) and

12 Dec 2016 · Meeting with Natural Gas Vehicles Association (NGVA)

Meeting with Pierre Schellekens (Cabinet of Vice-President Miguel Arias Cañete)

23 Feb 2015 · Energy Union and Climate Action