The document summarizes ENGVA's response to the European Commission's Green Paper on energy security. It argues that the Green Paper raises questions that have already been answered in previous Commission reports, such as the need to reduce dependence on imported oil through alternative fuels like natural gas. The document calls for the Commission to take action on these existing recommendations by developing an action plan and strategy, and to provide more support for natural gas vehicles through policy leadership, regulatory actions, research funding, and balanced communications about alternative fuels.

1. NGVs for a Better Climate; A Better Climate for NGVs
Brussels, 27 March 2006
ENGVA Response to:
Green Paper on
Secure, Competitive and Sustainable Energy for Europe
The ambitious European Commission Green Paper on Secure, Competitive and Sustainable
Energy for Europe (8 March 2006) lays out some broad objectives for a more secure energy future in
Europe but, unfortunately, raises more questions than it answers. It is puzzling that the Green Paper
continues to raise questions that already have been answered in other European Commission policies,
yet remain overlooked in this new document. With ambitious goals in mind, ENGVA asks whether or
not, with this new Green Paper, the Commission continues to chase its own tail.
The Green Papers asks: “Should Europe define a road map to reduce its dependence on
imported oil with key initiatives on energy efficiency in the transport sector and alternative motor
fuels?” It also asks: “Should decisions on targets or objectives beyond 2010 be taken in order to
provide a long term prospective to industry and investors?”
For the transportation sector, both these questions have been answered by the European
Commission’s December 2003 report, “Market Development for Alternative Fuels.” In this document,
produced by stakeholders to support ambitious fuel replacement targets in the transportation sector to
2020, the Commission has already defined its so-called road map to reduce dependence on imported
oil: Replace 10% of the petroleum consumed in the transport sector by 2020 with natural gas; 5-8% with
biofuels, which includes biogas; and approximately 2% with hydrogen. This analysis already has
indicated that: 1) A European approach is required to achieve these ambitious fuel replacement targets;
and 2) natural gas is the only fuel among the alternatives for the transport sector that can be expected
to replace more than 5% of the petroleum by 2010.
Why then is this new Green Paper asking questions that already have been answered, but
upon which little action has been taken?
• A natural gas car reduces green house gas emissions/CO2 over an equivalent petrol car by
20-25%; clearly a technology whose time has come as one of the contributors to reduced
global warming.
• Biogas made from renewable resources such as agricultural waste and urban waste (also from
wood, grass, etc.) and upgraded to biomethane as a vehicle fuel could replace as much as 20-
35% of the petroleum in the transport sector with an indigenous European fuel solution that
addresses substantial waste management issues as well CO2 reduction. Unfortunately, most
of the efforts by the European Commission focus on liquid ‘bio-fuels’, most of which at this time
are being imported from Brazil in the form of ethanol. As such, biomethane and natural gas for
vehicles addresses the Green Paper questions about increasing the use of clean and
indigenous energy sources.
• According to a December 2005 European Commission Well-to-Wheel study, “The conversion
of biomass into conventional bio-fuels is not energy-efficient. Ethanol and bio-diesel require
more bio-energy than the fossil energy they save.”

2. From ENGVA’s perspective it is time to transform the new Green Paper into an Action Plan
and Strategy that addresses the important solutions already identified by the Commission and move on
to achieve the goals already established.
Specifically, in relation to NGVs, market development to the Target 2020 would be greatly
helped if the European Commission were to concentrate on the following areas:
Policy leadership
• A directive on the Strategic Market Development of Natural Gas and Hydrogen Vehicles is
needed to provide accountability of member states to achieve the specified fuel replacement
targets that demonstrate commitment to long term energy security. NGVs are a solution today
and are a pathway to hydrogen vehicles into the future.
Regulatory action
• Prevent regulatory roadblocks in Euro 5 & Euro 6 (i.e. create a non-methane hydrocarbon
(NMHC) regulation that recognizes NGVs potential to reduce ozone and smog-forming
emissions by 85%)
• Continue the Environmentally Enhanced Vehicle (EEV) target standard in heavy duty vehicle
regulations (HDVs) and expand it to apply to light duty vehicles (LDVs)
• ‘Deregulate’ natural gas as a listed European pollutant in current EC regulations
Better balance from EC communications on alternative fuels
European Commission publications have consistently ignored and undervalued natural gas
and biomethane as vehicle fuel options. For example, the 2003 Biofuels Directive says, “Increased use
of biofuels for transport, without ruling out other possible alternative fuels, including automotive
LPG and CNG, is one of the tools by which the Community can reduce its dependence on imported
energy…” This is not a ringing endorsement for natural gas vehicles, even though biomethane could
replace 20-35% of the fuel in the transportation sector. Clearly this reflects the type of ‘liquid bias’ on the
part of the Commission that thwarts NGV market development instead of supporting it enthusiastically.
Unfortunately, the EC tends to view biogas as a fuel for electric generation and its use as biomethane in
vehicles is not advocated.
Increased RD&D funding
The NGV industry suffers from a lack of research and development funding (€2 - 8 million for
6th framework demonstrations) while €260 million is being spent on hydrogen and €66 million is spent
on almost exclusively liquid biofuels. Areas of important NGV research and development include, but
are not limited to:
• Vehicles, engines & fuel storage
• Fuelling stations, gas composition
• Upgrading of biogas to biomethane for vehicles
• Development of LNG vehicle standards (CEN)
• Continued support for methane reformation to hydrogen
The European Commission is on the right track to create a reasonable energy strategy. What
is needed now is a sharper focus on natural gas and biomethane in vehicles as an immediate step
toward a long term, sustainable energy strategy for Europe.
For further information, please contact:

3. Dr. Jeffrey M. Seisler
Executive Director
European Natural Gas Vehicle Association (ENGVA)
813A Kruisweg
Hoofddorp 2132NG
The Netherlands
Tel: 31.23.554.3050
Fax: 31.23.557.9065
Email: jseisler@engva.nl
Visit: www.engva.org