Interpretation ID: nht93-6.21

DATE: August 19, 1993

FROM: Richard A. Wennerberg -- Vice President, Marketing Services, American Gas Association

TO: John Womack -- Acting Chief Counsel, NHTSA

COPYEE: Rich Kolodziej -- A.G.A.; Paul Duvall -- Brunswick

TITLE: None

ATTACHMT: Attached to letter dated 10/22/93 from John Womack to Richard A. Wennerberg (A41; Std. 303)

TEXT:

On behalf of the American Gas Association (A.G.A), I would like to express our appreciation to the persons at the National Highway Traffic Safety Administration (NHTSA) responsible for convening the recent meeting to discuss the status of the compressed natural gas cylinder rulemaking. We are hopeful that the meeting and the planned follow-up actions will result in the speedy resolution of this issue. The implementation of a final rule will serve to allay some of the concerns that currently are impeding the marketability of natural gas vehicles.

As stated at the meeting on Monday, the lack of standards is a problem for vendors and manufacturers that are seeking to use or sell natural gas cylinders. Some state and local officials are hesitant at this time to commit to natural gas vehicles due to the lack of acceptable federal standards. There appears to a perception by some state officials that the existing Department of Transportation regulations (those adopted by the Research Special Programs Administration) apply to (Vehicular cylinders i.e., cylinders designed to store a vehicle's supply of fuel. Many state planning agencies and federal authorities are in the process of finalizing or implementing alternative fuel programs. As a result, equipment manufacturers are working aggressively to meet the expected demand for alternative fuel vehicles. We are concerned that officials will overlook the attractive advantages of natural gas vehicles due to the misperception that our products do not meet existing standards.

With regard to this misperception, A.G.A. would like to request that your office write a short letter clarifying this issue. One of our staff attorneys has spoken with Mr. Woodford regarding our concerns. Mr. Woodford recommended that we should forward our request to your office. Such a clarification could simply explain that the existing standards were not designed with vehicles in mind and that NHTSA is currently in the process of developing federal standards for compressed natural gas cylinders.

If the agency feels more comfortable sending the letter to state officials instead of to myself, A.G.A. would be happy to supply NHTSA with the relevant names and addresses. We would ask that A.G.A. be copied on any such letter. Thank you for your attention to this matter. I look forward to hearing from you.