A new bill being considered in Washington State would delay, for at least a couple of years, implementation of proposed rules that constrain crediting of avoided-methane offsets in the state’s Clean Fuel Standard (CFS). These offsets expand the scope of greenhouse gas (GHG) accounting for renewable natural gas (RNG) pathways to include avoided emissions from agricultural waste management and organic waste diverted from landfills. While RNG from waste is a low-GHG resource suitable for producing alternative fuels, such offsets divert CFS support to the agricultural sector and away from transport, the largest source of GHG emissions in Washington State.

That means the constraints on the offsets, which were proposed by the Department of Ecology, are important safeguards. Any delay would endanger the effectiveness of the CFS. Let’s review why.

The ICCT has extensively highlighted issues with unrestricted avoided-methane offset crediting for RNG in clean fuels programs, and California indeed adopted some restrictions in its recent Low Carbon Fuel Standard (LCFS) rulemaking. Washington’s proposed CFS update follows suit and would introduce a 15-year limit on avoided methane crediting for each RNG project. It would also require that participants demonstrate that at least some RNG is physically flowing into Washington; this starts in 2032 for fuel used in vehicles and in 2037 for RNG used for production of other alternative fuels. But there’s also a provision in Senate Bill (SB) 5601 that would override these safeguards, at a minimum through 2026. Its language targets RNG used for producing sustainable aviation fuel (SAF). But the proposed rules are not SAF-specific. Therefore, the safeguards could be jeopardized if SB 5601 is adopted as currently written.

There are two primary reasons for the concern. First, for as long as avoided-methane offsets are in use, a fuels program is not technology neutral because it allows some pathways to benefit from offset accounting but not others. A recent ICCT paper highlighted this issue by demonstrating the excessive policy value of avoided-methane hydrogen pathways under the LCFS compared with a technologically advanced green hydrogen pathway with near-zero in-sector emissions. Under a $75-per-credit scenario, dairy-RNG hydrogen in California could receive $3.30 per kg in credits compared with only $1.40 for green hydrogen. Similar outcomes are expected when comparing RNG-based SAF production with more scalable advanced solutions like e-kerosene, which is already being pioneered in Washington State. If the provision in SB 5601 that overrides safeguards on avoided-methane offsets takes effect, CFS support for innovative transportation technologies like e-kerosene could instead be diverted to pathways that rely on avoided-methane offsets.

Second, avoided-methane offsets can endanger the stability of a fuels program by disrupting the balance between the supply and demand of credits. This happens because offsets can enable deeply negative carbon intensity values that lead to a decoupling of credit generation from the supply of fuel. In other words, credits would be generated not from displacing fossil fuel, but from crediting changes in manure management practices at farms across the country. As shown in the figure, credit generation from dairy digester/animal waste compressed natural gas in the LCFS rapidly outpaced fuel volumes. In the second quarter of 2024, dairy and swine RNG generated 20% of program credits while making up only 3% of the alternative fuel used in California. This oversupply has contributed to a growing credit bank and declining LCFS credit values.

With credit values in the Washington CFS already declining to $22.93 per MT in January 2025, an influx of methane-offset-supported, negative-carbon-intensity RNG pathways would drive the price down further. This could severely damage the CFS’s ability to support in-sector emission reductions. In particular, low credit prices could stymie any CFS support for zero-emission vehicles and charging infrastructure aligned with Washington’s ambitious Clean Vehicles Program. This support is especially critical now that federal support for zero-emission vehicle adoption and charging infrastructure deployment is in question.

Allowing avoided-methane offsets without restrictions is all risk and no reward. It has the perverse effect of providing greater incentives to pathways that have less impact on in-sector emissions. If any language in SB 5601 serves to prevent or delay the implementation of the proposed safeguards, this would be the likely, unfortunate outcome.

This piece originally appeared in Punjab Kesari in Hindi.

For many reasons, Haryana is the automobile hub of India. Its electric vehicle (EV) policy, which began in 2022, marked a significant step toward reducing transportation emissions. Now more than 2 years into the 5-year policy, with the Government of India having released the Production Linked Incentive (PLI) scheme for the National Programme on Advance Chemistry Cell Battery Storage and the PM Electric Drive Revolution in Innovative Vehicle Enhancement (PM E-DRIVE) scheme, there’s a prime opportunity for Haryana’s new government to make strides in promoting EV adoption, particularly for electric cars.

Here are four areas where extra focus could help maximize the potential for success:

1.  Grow the charging infrastructure network. While Haryana’s EV policy promotes setting up charging points in designated urban areas, implementation has been relatively sluggish. For drivers of electric cars in particular, public charging stations are needed in cities and along major highways to make them feel most confident. This is a learning from regions with the highest EV adoption rates, and one example is Norway’s successful model, which ensures charging stations every 50 km on main roads. Norway has one of the world’s highest ratios of chargers to vehicles with 30 public chargers per thousand electric cars and vans. A focus on standardized public charging stations compatible with various EV models and on installing fast chargers would reduce time that drivers spend waiting for a charger, particularly in high-traffic areas, parking lots, and commercial hubs. As we outlined here, charging infrastructure standardization is crucial because it reduces investment costs through economies of scale and significantly improves user experience.

In addition, Haryana can complement Central Government funding available for charging infrastructure in PM E-DRIVE with its own financial incentives for installing home and workplace chargers. Norway’s experience was highlighted at our India Clean Transportation Summit 2024, where Markus Nilsen Rotevatn from the Norwegian EV Association explained that a suite of policies have combined to make EVs in Norway so cost-effective that consumers are choosing them for that reason alone.

2. State manufacturing and research and development (R&D) initiatives for EVs. Haryana’s many strategic advantages—proximity to key markets, robust road infrastructure that provides reliable connectivity to other parts of India, dedicated EV parks, and skilled manufacturing workforce—mean it’s well positioned to become an EV manufacturing hub. The government can offer financial incentives to attract investment from local and global EV manufacturers, battery producers, and component suppliers. One avenue is special economic zones (SEZs) for EV production, which are designated areas that provide benefits like tax exemptions, streamlined customs processes, and access to superior infrastructure. These zones can enhance productivity, reduce operational costs, create job opportunities, and contribute to economic development. In Haryana, such SEZs could be complemented by R&D centres that focus on advancing EV battery technology and cost-effective EV components through public-private partnerships with local universities and technical institutions.

3. Financial incentive structures. Though Haryana’s EV policy includes purchase incentives for electric two-wheelers, three-wheelers, and cars, registration fee waivers, and road tax exemptions, there are ways to expand the financial benefits. Taking cues from successful global models in the United States, the United Kingdom, and China, Haryana’s government could collaborate with financial institutions to offer low-interest loans for EV buyers and give them more time to repay EV loans. Additionally, the government could create a financial risk management fund from the State Transport Fund for Accelerating EVs and support banks that lend to middle-class buyers and fleet operators. This could be especially effective now, as interest rates are not low. A fixed percentage of the State’s Transport fund could be allocated to things like providing purchase subsidies, developing charging infrastructure, and electrifying public transportation. The fund can also be used to provide free parking or reduced tolls.

4. New regulatory frameworks and building codes. Following models from Europe, Haryana could consider introducing low-emission zones (LEZs) in pollution-heavy cities like Gurugram and Faridabad. LEZs are geographically defined areas where access restrictions are applied to polluting motorized vehicles. The importance of LEZs was highlighted recently in a convening organized jointly by the Government of Haryana Transport Department and the ICCT. The Haryana Pollution Control Board mentioned LEZs in its Winter Action Plan 2024–25, but action on the ground has yet to commence. Updating building codes to require that new residential and commercial buildings be EV-ready and mandating that government departments transition to battery electric vehicles within a specified time frame are other ways to support the market.

Several supplementary measures would also support these priorities. From public-awareness campaigns that leverage multiple channels including television, social media, and community events, to educational programs in technical institutions that focus on EV technology and a robust battery recycling infrastructure with appropriate regulations, such measures work together to create a supportive ecosystem that enables widespread EV adoption.

Delivering on the vision in Haryana’s EV policy is expected to generate substantial environmental and economic benefits, including significant reduction in vehicular emissions, improved air quality across urban centres and avoided premature deaths through reduced air pollution, job creation across the EV value chain, and the positioning of Haryana as a competitive EV manufacturing hub in North India. The state EV policy complements the National Electric Mobility Mission Plan’s goal of 30% EV penetration by 2030 and strengthens India’s commitment under the Paris Agreement to reduce emissions intensity by 45% by 2030. While this agenda is ambitious, the long-term benefits to public health, employment, and economic growth make this transition not just desirable but imperative for Haryana’s sustainable future.

This piece was originally published in the Hindustan Times.

Road traffic congestion is a pressing issue in many of India’s metropolitan centres. Gridlock brings prolonged commute times, excessive fuel consumption, air and noise pollution, and elevated greenhouse gas emissions. The National Capital Region has been in the spotlight as traffic has worsened with urban sprawl. According to research published by the International Council on Clean Transportation (ICCT), on-road vehicles were responsible for nearly three-quarters of the transportation health burden in New Delhi in 2015.

To address peak-hour congestion, Delhi’s government reportedly plans to introduce a pilot congestion tax that would charge drivers who use select roadways during busy periods. Also known as congestion pricing, this aims to ease traffic and reduce pollution by discouraging unnecessary trips and encouraging drivers to use alternative routes, travel at off-peak times, shift to public transport, or share rides (and fees) with others. A 2010 study by the ICCT found that congestion tax schemes in London, Singapore, and Stockholm reduced congestion by 13%–30% and greenhouse gas emissions by 15%–20%.

This isn’t the first time Delhi has considered congestion pricing. Proposals in 2009 and 2018 failed to advance. Still, as Delhi looks ahead to its congestion tax pilot, I’ll highlight experiences from other cities that can provide valuable insights into how these schemes could be employed to effectively reduce traffic and air pollution.

Dynamic pricing

Delhi’s pilot would reportedly charge vehicles entering the city at 13 major entry points during morning and evening peak hours. With over 1.1 million vehicles entering and exiting daily, this makes sense, as such corridors are often heavily congested. A 2016 Centre for Science and Environment (CSE) cross-border traffic survey at nine major entry points to Delhi accounting for about 70% of traffic into the city found that the number of personal and passenger cars and two-wheelers entering daily was about the same as the number of vehicles registered in the city in a year.

At the same time, with over 1,800 new vehicles added to the Capital’s roads daily, an entry-point congestion tax during peak hours could miss an opportunity to address a large portion of daily vehicle emissions. Another CSE study estimated that the traffic at surveyed border points contributed just 10% of the total pollution loads emanating from the transport sector in Delhi. Administering taxes only at peak hours can also mean overlooking emissions during off-peak times, including those from heavy-duty vehicles, which are responsible for 20%–30% of transport sector pollution in Delhi and operate predominately outside of peak hours.

Other countries have sought to balance pollution and emission reduction aims against commuter access through dynamic pricing schemes that apply city-wide and have fees that rise at times of high congestion and drop during less busy times. In Singapore, an early pioneer in congestion pricing, charges are regularly reviewed and adjusted in response to changes in traffic patterns. Rates vary throughout the day and rise and fall gradually around periods of high traffic, which helps avoid surges before and after the designated peak hours.

Targeting the most polluting vehicles

Delhi reportedly plans to impose charges on most vehicles but exempt two-wheelers and electric vehicles. Congestion pricing programs in other countries have also provided discounts or exemptions for certain travelers, such as for residents of the designated taxation area, diplomatic vehicles, and emergency vehicles.

However, in Delhi, discounts and exemptions for any personal or commercial vehicle may risk undermining the core congestion and emission reduction aims of the schemes. For instance, two-wheelers, with reportedly about 1,100 new registrations  each day,  are roughly one in three vehicles on the road and are the second-largest contributor to transport pollution, according to The Energy and Resources Institute. Lessons can also be drawn from Delhi’s own 2016 odd-even scheme, which aimed to reduce pollution by restricting the operation of vehicles based on license plate number and exempted two-wheelers, women-only vehicles, and taxis, among others. Observers assessed that the program had minimal impact on pollution due in part to an increase in the use of exempted vehicles.

Pricing framework

Policymakers in other countries have wrestled with how to set congestion charges high enough to encourage reductions in vehicle use without placing a disproportionate financial burden on low-income travelers. In the 1970s, Singapore’s congestion toll led to a larger-than-expected drop in traffic that raised commuter welfare concerns. More recently, London revised its fee upward to maintain effectiveness in response to inflation.

There are other strategies. Currently, pricing in Singapore and Milan’s Area C varies by vehicle size and heavier, more polluting vehicles pay higher charges than lighter ones. This reflects their greater impact on both traffic congestion and pollution levels. Remote sensing, a method used to monitor real-world tailpipe emissions, could offer support for tailoring congestion prices to the emissions of different vehicles. This technology has been deployed in Europe, the United States, Spain, Sweden, and elsewhere to identify high- and low-emission vehicles and detect possible vehicle tampering. A recent ICCT study that took measurements via remote sensing in Delhi and Gurugram highlighted the difference between real-world tailpipe emission levels and laboratory limits and the need for advanced techniques for emissions monitoring.

A review of congestion pricing pilot programs in U.S. cities identified a number of possible approaches to mitigate the impacts of these schemes on low-income groups, including discounts, exemptions, and rebates. Such measures aim to minimize the financial burden on disadvantaged communities while maintaining the program’s effectiveness. Additionally, cities like Bogotá (Colombia) have adopted approaches that consider drivers’ income level alongside vehicle emissions to establish an equitable pricing structure.

The role of public transportation and supportive policies

Delhi has more than 7,500 buses in operation and over 390 km of metro connectivity, including links to other major cities. Still, challenges persist, including irregular bus frequency, overcrowding during rush hours, poor conditions of the bus, and last-mile connectivity issues for metro users. Ensuring that the public transit system is reliable, well-integrated, and equipped for last-mile connectivity through feeder bus services and pedestrian and cycling infrastructure is critical to realizing the shift away from private transport envisioned under congestion tax schemes. Indeed, congestion pricing was also considered recently in Bangalore and Mumbai, but it stalled due to concerns about the capacity of the public transport system to provide sustainable alternatives to private vehicle users.

Other cities have used revenues from congestion pricing to pay for upgrades to the public transit system. In London, the net revenue from congestion pricing has supported efforts to enhance bus fleets, expand bicycle and pedestrian lanes, improve road safety, and more. Cities like London, Paris, and Brussels have implemented scrappage programs that provide subsidies to retire older, higher-emitting vehicles and encourage a shift to public transit or cleaner private vehicles. Furthermore, initiatives like Delhi’s Mohalla bus scheme, a feeder bus service designed for neighbourhood-level operations, are expected to bridge the last-mile connectivity challenges by deploying 9 m zero-emission buses at scale.

In considering congestion taxing to help address poor air quality, Delhi has the opportunity to draw on global insights and establish a strong precedent for tackling traffic congestion and air pollution together. Success in this would promote sustainable urban mobility that offers a safer, healthier environment for its residents.

A recent report by the North American Council for Freight Efficiency (NACFE) highlighted the role of natural gas as a transport fuel and estimated that the greenhouse gas (GHG) emission savings from a natural gas engine are in the range of 13%–18% compared with diesel fuel. However, NACFE “focused most [its] discussion on the tank-to-wheels effects of the alternate fuels” in comparing a natural gas-powered truck with a diesel truck doing the same route. An analysis of the complete fuel-cycle GHG emissions (i.e., well-to-wheel) would cover emissions associated with all the steps of producing, transporting, and consuming the natural gas and diesel used for those trucks. As I’ll show here, the emission impacts of the upstream natural gas supply chain complicate the climate benefits of using natural gas for trucks.

The primary issue is methane leakage. Natural gas is mostly methane (85%–90% by volume) and its production involves multiple steps during which methane could be released into the atmosphere through leaks and venting. This happens all along the supply chain and these upstream emissions are noteworthy because methane is a potent GHG.

Upstream methane emissions can be substantial and they’re not easy to estimate. For example, using ground-based measurements validated by aircraft observations, researchers have estimated that methane emissions from the oil and natural gas (O&NG) industry are much higher than previously estimated by the U.S. Environmental Protection Agency (EPA). Methane emission estimates reported in EPA’s national GHG inventory are based on adding up the emissions from individual components of natural gas production equipment. Although this kind of bottom-up methodology provides detailed data from routine equipment behavior, it does not detect super-emitters, which can be unpredictable and can emit unusually large amounts of methane (one example is malfunctioning equipment). Alternate measurement approaches such as remote sensing of methane emissions via satellites or aerial surveys can help cover vast areas and detect these super-emitters, but such top-down emission estimates can also overestimate emissions. For instance, this technique might not be able to differentiate between O&NG sites and other sources of methane, such as landfills or dairy farms.

It’s also important to differentiate between emissions from combined O&NG production and emissions from producing just natural gas. For sites that produce both fuels, part of the methane emissions should be attributed to the oil produced alongside natural gas on an energy-weighted basis. The left column in Figure 1 illustrates the range of methane losses from O&NG production normalized by natural gas production using data from recent literature. These losses are calculated by dividing methane emissions by the amount of methane produced. The data from both bottom-up (e.g., EPA) and hybrid methodologies (i.e., a mix of bottom-up data and satellite or aerial surveys) were used for these estimates. The methane loss estimates in the right column in Figure 1 illustrate the emissions allocated solely to natural gas production, so they are allocation-adjusted loss rates. When the O&NG sector is considered, the methane loss rate ranges between 0.4% and 9.6%, with a mean of 3.4%. When losses are allocation adjusted, it ranges between 0.4% and 4.8%, with 1.8% as the mean.

Note: Methane emissions from O&NG production are from Alvarez et al. (2018), EPA (2024), and Sherwin et al. (2024). Methane emissions allocated to NG production are from Omara (2018) and Sherwin et al. (2024). 

To understand the climate impacts of upstream methane losses, let’s explore the fuel cycle GHG emissions of natural gas-powered heavy-duty trucks. Figure 2 illustrates the differences in well-to-wheel GHG emissions for 40-tonne trucks that run on compressed natural gas (CNG), normalized per mile, for each fuel option analyzed. We used the mean methane loss rate for natural gas production (1.8%) as well as the minimum (0.4%) and maximum (4.8%) loss rates from Figure 1 to provide the range of emissions estimates indicated by the error bar. The fuel economy of a heavy truck running on natural gas of 6.5 miles per diesel gallon equivalent was taken from the NACFE report. To compare our analysis with diesel-powered trucks, we used the U.S. national average for the carbon intensity of diesel fuel from the U.S. Renewable Fuel Standard, 91.9 g CO₂e/MJ. Non-CO₂ tailpipe emissions (methane and nitrous oxide) from GREET 2023 were included as equivalent amounts of CO₂ in the combustion emissions for diesel and natural gas-powered trucks. The system boundary for natural gas includes extraction, processing, transport, fuel refining and distribution, and methane leakage for all steps. As illustrated in Figure 2, with the mean methane emissions rate of 1.8%, our estimates are a 6% GHG emission savings from CNG trucks compared with diesel ones. However, the same estimate shows that if there is a methane leakage rate greater than 2.5%, that would make CNG trucks worse than diesel ones from a climate perspective.

Note: Fossil CNG results are estimated using GREET 2023 and assumptions therein for CNG production and combustion in dedicated CNG-fueled vehicles using a 100-year global warming potential for greenhouse gases. 

Thus, even with optimistic assumptions for upstream methane leakage, we estimate that CNG trucks only offer mild GHG reductions, if any, compared with petroleum diesel. This means that the estimated GHG savings for switching to natural gas trucks are marginal at best. However, there is also a long-term problem: Purchasing natural gas trucks may create technology lock-in. The CNG trucks purchased today and in the next several years could be on the road well into the 2030s, when zero-emission vehicles that provide much larger emission benefits could be more widely available. Battery electric trucks using grid-average electricity already generate deeper GHG savings than CNG trucks in many regions, and these GHG savings will grow over time as the grid decarbonizes. Adopting CNG could mean foregoing substantial GHG savings in the future from zero-emission vehicles.