22. Scania proposed that the LNG tank be excluded from the ground clearance requirement because they generally are manufactured from stainless steel like diesel tanks, which have been approved by ECE R.34. Also, since the LNG tank consists of an inner tank and outer tank the redundant structure for external leakage is, therefore, decreased. Comparing stainless tank LNG tank compared to a composite tank, where lower level fiber wrap is damaged, the danger potential for an LNG tank is much lower than for a CNG tank, thus should be excluded from the ground clearance requirements. Also, diesel tanks have the lowest ground clearance (130-140mm) up to the tank.

23. Mr. Ursan noted that the North American code considers when the vehicle has a flat tire (or two flat tires). The standards specify that the tank does not come in contact with the ground, in order to prevent damage to the tank. This has been the rationale for specifying ground clearance.

24. Question from Scania: If the tank would be damaged to leakage if the tank came into contact with the ground in the case of a flat tire.

25. Mr. Dijkhof also asked how to handle the use of LNG on a low floor bus.

26. Mr. Seisler suggested that no specified millimeter requirements be provided but that regulatory language should merely specify that under no circumstances (flat tires/speed bumps, low floor buses, etc.) should the LNG tank comes in contact with the ground. This has to be ensured by the vehicle manufacturers (or retrofit installers).

27. Mr. Dijkhof suggested that Scania provides new language to accommodate this suggestion.