Discussion regarding the regulatory strategy to develop a completely new L-NGV regulation or create amendments to R.110: The group tends to be in favor of amending R.110 with the aspects specific to LNG become another ‘part’ of R.110, for LNG only. Having done that, moving to a Global Technical Regulation (GTR) would be easier. There cannot be an annex but could be done in a separate part. One part would have a common branch with CNG and another part would be LNG-specific.

Timing becomes one of the key issues. A new regulation would take an additional two years to create due to the fact that it would have to be approved by the European Union. From the equipment suppliers’ view the timing of a final regulation into 2015 is ‘not acceptable’ (or preferable). It might be better to have something that moves toward worldwide harmonization through R.110. This also could lead later to the development of a Global Technical Regulation (GTR) if this would help in the marketplace.

Discussion about boil-off versus venting, and concerns about vehicles parked inactive for days without driving, particularly if they are in a closed garage. From a presentation by Westport at the LNG Task Force the distinction was made that, “The vapours created due to the ambient heat input (while maintaining constant pressure in the storage vessel) are called “boil-off”.“ The discharge of these vapours out of the storage container is called venting. The question of how or if to regulate the boil-off in R.110 is discussed at length:

• - Clearly venting is a safety concern but boil-off is an operational consideration and, as such, might not be appropriate to regulate in R.110.
• - Should the ‘holding time’ be specified in the regulation since this relates to the ‘performance’ of the LNG tank?
• - Could specify a ‘not-to-exceed’ pressure in a tank, although venting is the technical measure designed to prevent excessive pressure and does not need to be regulated.
• - A question is raised about the effects of ambient temperature on the tanks, which is a factor, however, the heavily insulated cryogenic tanks are designed to mitigate and diminish the effects of ambient temperatures. Such effects would need to be verified.
• - ‘Educated management’ of the cryogenic systems is more important sometimes in determining ‘holding-time.’ Different volumes of fuel in the tank also will affect holding time.
• - It is suggested that R.110 could specify that the manufacturers provide guidance through a user manual on holding-time, boil-off, and venting.
• - Carriage of LNG trucks on ferries becomes a challenge in light of venting considerations.
• - Since vehicle owners see venting as money going (literally) into the air, there is an automatic motivation to limit venting as well as boil-off.
• - Mr. Renaudin will attend the next meeting of the LNG TF where this issue will be discussed again.

Vehicle Labeling

Labeling of vehicles was an issue discussed at the LNG TF, noting that car manufacturers do not like labels on their vehicles but trucks already are labeled so it is not a problem for HDVs. It is noted that, for regulatory purposes, amendment language has been set already dealing with engine labels and that is deemed enough.

Jeff Seisler, Co-Secretariat of the LNG Task force made a brief report to the group that is a shortened version of the last report to the GFV (see document (GFV16-05 (NGV Global LNG TF-2 Report)

Genesis of the group: Follows the need created by the GFV/HDDF TF work on dual-fuel systems, which includes the use of LNG. While GFV deals with R.115 and the new LNG regulations are within R.110 (under Group of Experts on General Safety – GRSG), the LNG TF is following ‘the line’ upward within the GFV umbrella yet recognizing that all reports, decisions, amendments etc. must go through the GRSG.

Main activities: Doing a line-by-line review of R.110 to include LNG language, loosely falling into three ‘categories’: Simple changes (low hanging fruit); more complex issues needing more consideration and analysis; completely new and different elements unique to LNG that will be put into a separate ‘LNG Annex.”

Key Issues: 1) Components versus systems (detailed specifications needed for some regulatory bodies); 2) venting and boil-off, both related to additional methane fraction into the atmosphere (likely not to be a big problem); 3) vehicle labeling; and, 4) a procedural issue: whether R.110 should be amended to incorporate LNG provisions or if an entirely new LNG ‘companion’ to R.110 should be created.

On this issue the pros and cons are: 1) amended R.110 may be faster and all the existing R.110 language would not have to be copied/duplicated into a new LNG regulation; and 2) in favor of creating a new regulation it would be a ‘stand-alone’ LNG document that might be more easily dealt with by GRSG but the regulation would be subject to a co-decision process within the European Union and that could add two years to the adoption of the new regulation. Increasing the time for adoption of new regulations is less desirable to the industry. The LNG TF is on track to amend the existing regulation but the issue will be more closely debated at the next LNG TF meeting on 8 February 2012 in Brussels.

On the issue of amendments versus a new LNG regulation Mr. Rijnders indicates that Contracting Parties must be prepared to consider these new changes to ensure that they are appropriate for both CNG and LNG.