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COUNTY OF ULSTER
P.O. BOX 1800
KINGSTON, NEW YORK 12402
MICHAEL P. HEIN
COUNTY EXECUTIVE
DEPARTMENT OF THE ENVIRONMENT
17 Pearl Street, Kingston NY
Phone: 845-338-7287
Fax:
845-338-7682
AMANDA L. LAVALLE
COORDINATOR
ALANNA HENNEBERRY
DEPUTY COORDINATOR
MEMO
To:
From:
Date:
Subj:
Michael P. Hein, County Executive
Amanda LaValle, Department of the Environment
February 20, 2015
Liquefied Petroleum Gas Conversion Proposal- Resolution No. 314A
Summary and Opinion
The Department of the Environment has carried out a thorough technical review of the claimed financial
and environmental benefits of converting five inmate transport vans from conventional unleaded gasoline
to liquefied petroleum gas (propane). The review clearly demonstrates that the proposed conversion does
not yield the environmental or financial benefits claimed by members of the Ulster County Legislature.
The Department also has concerns regarding the operation, maintenance and regulation of converted
vehicles which warrants significant consideration.
It is the opinion of the Department of the Environment that this proposal is not a step in the right
direction for Ulster County’s fleet. The County Executive’s focus on right-sizing, efficient use, and
sustainable alternative fuel technologies (including, hybrids, plug-in hybrids and biodiesel) for the fleet
will yield greenhouse gas (GHG) emission reductions and fiscal savings orders of magnitude greater than
the LPG proposal. In addition, the replacement of a single van with a fuel efficient option would yield
greater GHG emission reductions than the conversion of all the inmate transfer vans to propane.
Background
In August, Chairman Parete and Minority Leader Ronk provided a proposal to the County Executive’s
office to pilot the use of liquefied petroleum gas (propane) in the Sheriff’s inmate transport vehicles. The
proposal was subsequently followed by Resolution No. 314A to implement the proposal which was passed
by the UC Legislature on February 17, 2015.
Cost savings and environmental benefits were cited as the rationale justifying this proposal. The
conversion of the existing vans was stated to cost $5,000 per a vehicle for a total expenditure of $25,000.
As propane costs less per gallon than unleaded gasoline, the cost savings in the fuel is used to justify the
investment in the conversion. Significant reduction in emissions were also used as justification.
Financial Considerations
Cost Benefit Analysis
In the Department of the Environment’s review of the LPG documentation, the assumed prices for LPG
and gasoline (which is the foundation of the analysis) were found to not accurately reflect prices actually
paid in our area under NYS Office of General Services (OGS) contract. The price of both gasoline and LPG
on NYSOGS contract were reviewed for a period of eighteen months and the cost benefit analysis was
recalculated using actual price data. In that analysis, the payback time to recoup the initial $5,000
investment in the conversion nearly doubled 1.
•
•
Using the actual prices available to Ulster County on the NYS OGS bid 2, substantially less difference
was found between the cost of the two fuels ($1.14 per gallon) versus the assumption ($2.05 per
gallon) used in the provided analysis.
Rerunning the cost benefit analysis with more accurate price data yielded a payback period greater
than 5.8 years versus a payback period of 2.98 years using the legislative assumptions3.
Age and Efficiency of Vans
The Sheriff currently operates 9 vans which are on average 7 years old and have an average odometer
reading of over 50,000 miles. Any proposal to invest in retrofit technology for the vans should recognize
the overall age and condition of the vehicles. In general, the Department of the Environment contends
the overall fuel efficiency of the vans is truly the issue that should be addressed. The vans average about
11 miles per gallon and collectively travel approximately 45,000 miles a year.
•
Replacing one van with a more fuel efficient model could reduce overall fuel consumption (and GHG
emissions) of the van fleet by 12% (exceeding the 10% GHG emission savings for converting all the
vans to LPG) and would provide approximately $1100 a year in fuel savings.
The propane proposal obviously will not yield the financial benefits claimed and the investment of
$25,000 could better be spent on a newer more fuel efficient van.
Environmental Considerations
Greenhouse Gas Emission Reduction
The legislative proposal asserts very dramatic tail pipe emission reductions for certain types of
greenhouse gasses (GHGs) with the conversion to propane. However, it does not provide a standard
overall estimate in the reduction of GHGs (in CO2e, carbon dioxide equivalent) due to the propane
conversion. In addition, it is also part of a standard practice to consider the “upstream” emissions
related to any fuel combustion. This is the other GHG emission from the extraction, processing or
transport of a fuel. When using this standard method of analysis, the environmental benefit of the
propane conversion was found to be significantly less than that presented in the legislative proposal and
less than that which can be achieved by other more sustainable means.
1
This revised cost benefit analysis was provided to the UC Legislature in September 2014.
http://www.ogs.ny.gov/purchase/FuelsPricingDefault.htm
3
For a vehicle like the inmate transport vans traveling 10,000 miles per year and averaging 10 mpg.
2
•
•
Using NYSERDA standard metrics4, there would be between a 9 and 10% reduction in GHG
emission by converting the vans to LPG.
The conversion to propane would yield an annual GHG emission reduction of approximately
3.5mt CO2e 5 per year for the van fleet.
Although this reduction in tailpipe GHG emission is laudable, greater reductions will be made through
fuel efficiency measures and sustainable alternative fuels.
• The move to a B5 biodiesel blend in the UCAT buses will save 79.5mt CO2e annually 6. The
reduction due to B5 in the buses is over 22 times that of the LPG in the inmate transport van
fleet.
• The replacement of four existing sedans with plug-in hybrids will save approximately 13.2mt
CO2e annually. 7
• The installation of a network of charging stations at County facilities will promote electric and
plug-in hybrid vehicle use across Ulster County further reducing GHG emissions.
Propane from Fracking & Use of Sustainable Alternative Fuels
In addition, it is of serious concern the extent to which propane is being marketed by the natural gas
industry as an “alternative” fuel for transportation. This is obviously a way to increase the demand for
propane as domestic production has increased substantially due to the boom in high volume hydraulic
fracturing techniques for natural gas extraction.
•
In 2011, 69% of domestic propane production comes from natural gas production 8. It can be
assumed that this percentage is growing as natural gas production from fracking continues to
expand.
Although propane is domestically produced and plentiful due to the fracking boom, County resources
devoted to the conversion to alternative fuels should be for sustainable alternative fuels. Sustainable
alternative fuels are those that are derived at least in part from renewable resources such as electricity
generated from renewable sources, biodiesel, and hydrogen. Propane should not be considered a
sustainable alternative fuel.
•
•
Any initiative to introduce alternative fuel technologies should consider the sustainability of the
fuel including lifecycle energy and emissions as well as the renewability of the fuel source.
Ulster County has committed to using hybrid, plug-in hybrid, and sustainable alternative fuel
vehicles in our fleet and is in the process of installing plug-in electric vehicle charging stations at
nine public county facilities creating the most robust network of public charging stations in the
region.
Operation and Maintenance
Introduction of a new fuel type into the fleet requires that our fleet mechanics be able to maintain and
work on the equipment. Although there is great confidence in the capability of our fleet maintenance
4
Sources: Solid, gaseous, liquid and biomass fuels: Federal Register (2009) EPA; 40 CFR Parts 86, 87, 89 et al; Mandatory Reporting of
Greenhouse Gases; Final Rule, 30Oct09, 261 pp. Tables C-1 and C-2 at FR pp. 56409-56410. Revised emission factors for selected fuels: Federal
Register (2010) EPA; 40 CFR Part 98.
5
Metric tons of carbon dioxide equivalent; Calculated using NYSERDA metrics, see note 4.
6
Calculated using NYSERDA metrics, see note 4.
7
www.fueleconomy.gov
8
ICF International: prepared for the National Propane Gas Association (NPGS), Propane Supply Sources and Trends. August 2012.
division, their valuable and limited resources must be appropriately utilized as our fleet moves towards
improved operation and sustainability.
•
If new technology is to be introduced which will require additional training by the fleet
mechanics, it should be hybrid and plug-in hybrid technology. This would be in the long term
interest of fleet sustainability and would produce greater benefits than the introduction of
propane vehicles.
A review by the City of New York analyzing their purchase of over 6800 hybrid vehicles over the last 13
years shows that the incremental increased cost of hybrid vehicle purchases is more than offset by fuel
savings, reduced maintenance costs and increased auction values9. There is no data to suggest propane
retrofits will provide similar benefits to the fleet.
•
Hybrid technology is proven to yield financial savings as well as provide significant reduction in
GHG emissions.
In addition, the County was notified by DEC this week that there are strict regulations regarding the
aftermarket conversion of vehicles to operate on LPG. These regulations, contained in 6 NYCRR Part 218,
Emissions Standards for Motor Vehicles Engines Subpart 218-7 state that any aftermarket conversion must
meet either California emission standards or EPA emission standards and be carried out on an approved
vehicle. Violations of these standards are subject to fines of at least $500 for the first violation and up to
$26,000 for each subsequent violation.
•
Aftermarket conversion are highly regulated by NYS DEC and if incorrectly applied can result in
significant fines.
Conclusion
The propane proposal does not consider the underlying inefficiency of the transport vans and additionally
trades one fossil fuel source for another. It does not provide real financial or environmental benefits and
the Department of the Environment fully agrees with the County Executives initiatives which will invest in
more efficient alternatives and sustainable technologies. The Department firmly believes that these
initiatives will better position the County to continue to green the fleet operations and provide real
environmental and fiscal benefits.
9
http://www.nyc.gov/html/dcas/downloads/pdf/fleet/nyc_fleet_hybrid_report_june_2014.pdf