Letter From Tim Carmichael About The DGE Vote

From: Tim Carmichael [mailto:tim@cngvc.org]
Sent: Thursday, July 17, 2014 10:57 AM
Subject: National Conference of Weights and Measures Annual Meeting REPORT

Dear Board Members

As many of you know I spent the last 4 days participating in the National Conference of Weights and Measures Annual meeting in Detroit.

The disappointing news is that there were not enough votes to adopt a diesel gallon equivalent standard for LNG and CNG method of sale for natural gas in transportation.

The good news is there weren't enough votes to adopt a kilogram (or mass) standard as the method of sale either. [as feared this was presented as an alternative proposal at this meeting]

What Happened

• Our industry was well represented at the meeting by NGV America, ANGA, Clean energy, Pivotal LNG, CHART, BLU LNG and CNGVC.
• Collectively we covered the various committee meetings, answered questions, gave testimony, and urged the adoption of a diesel gallon equivalent (DGE) for LNG and CNG.
• When it came to the final vote yesterday afternoon we had enough state representatives vote for the DGE proposal (29 including California and we needed 27) but we also needed 27 delegates and only 14 supported. The delegates are other weights and measures regulators mostly from the county level of government. There is no limit to how many delegates can participate from a single state. About 40 delegates were in the room for the final vote; most of them seemed to be from California and Michigan.
• It is important to know that the proposal which was voted on called for natural gas to be measured and verified in a mass unit (pounds) but indicated in (what the consumer would see on the pump) in gallon equivalents.

Why I think the vote didn't go our way

• The bottom line is that most of the weights and measures regulators strongly believe natural gas should be measured AND sold in a mass units. Several of the state representatives that voted for the DGE proposal commented during the week that they were only voting for the gallon equivalent proposal because their Governor or agency director told them they had to.

Other concerns raised included – appropriate pump labeling language, the number of decimal places needed for the mass measurement, a "slippery slope argument" that this will lead to everything being sold in equivalent units [to support this last concern some cited that the LPG industry recently inquired about changing their unit of measure to gallon equivalents]; complaints about the process being too political; complaints about industry applying too much pressure.

What happens now

• For NCWM this issue goes back to the committee level; both to the Natural Gas Steering Committee and to regional meetings in the Fall
• I believe it is important for our industry to continue to engage with NCWM's but based on our experience this week I am skeptical that more discussion will lead to a significant change of perspective among this body over the next year.
• Several states are already working on and more indicated that they will now begin the process of developing regulations and/or legislation to create standards for DGE.
• In California passage of AB 1907 becomes even more important now. I will connect with board members who have been engaging on this legislation and review the Administration's proposed amendments in the new light of no action at the national level.

I want to note that the state representatives from Colorado, Florida, and Arkansas were particularly supportive and helpful all week.


Tim Carmichael, President