It's a safety issue. If you get rear-ended hard enough by some idjet, the fuel cell will compact and likely cause a fire in an otherwise survivable crash.If Gen-Right can make one for the TJ that fits in the rear frame rails and has some serious protection and carries 31 gallons of fuel why can't we have one for the JK? I've asked Gen-Right and they said they have been asked by DC to not build a tank for that location. However if we all send an email asking for a larger capacity heavily protected fuel tank to fit in the traditional TJ location maybe, just maybe they will build us some. I'd gladly loose that little trunk area for 10 or more gallons of fuel set in the middle of my JK and with some serious protection.
Placement of the fuel cells in vehicles have become a bigger issue due to a few lawsuits where someone sued due to a fire resultant from a crash. Notably GM trucks where their saddle-bag tanks were on the outside of the framerails and the multi-billion Dollar Chevy Malibu lawsuit where the fuel cells were deemed to be too close to the rear of the vehicle.