VTCCC Supports Regional Effort to Transform our Transportation Sector

January 10, 2019

On December 18, 2018, a coalition of nine states and the District of Columbia, including Vermont, announced their intent to design a new regional low-carbon transportation policy proposal that would cap and reduce carbon emissions from the combustion of transportation fuels, and invest proceeds from the program into low-carbon and more resilient transportation infrastructure. Find the announcement here and advocate responses to announcement here.

The T4VT Coalition, which VTCCC is a member of, is excited about the commitment by Vermont and other states, working as the Transportation Climate Initiative, to thinking regionally about the environmental impacts of our transportation system.  In Vermont, transportation is currently the least renewable energy sector and the largest source of pollution in the state, generating 42% of our greenhouse gas emissions.

Harnessing market-based solutions, as well as fostering regional collaboration, are extremely important considering how much of our energy/GHG comes from transportation, and considering the pressing problem of climate change.

We know that transportation is a complex system, influenced by key factors like the locations of our homes, jobs, schools, and businesses, as well as by people’s socioeconomic status. As a system that we have built over many years, it will take time and strategic investment to shift. 

A cap and invest system could provide some of the revenue needed for that investment. Investment is essential not only for new technologies like electric vehicles and on-demand ride sharing, but also for housing in villages and downtowns, as well as walking and biking infrastructure.

T4VT sincerely hopes this important conversation and process will be an open and transparent one. We look forward to monitoring the progress of this project and to reviewing and commenting on the proposal.

Transportation for Vermonters is a broad coalition committed to increasing the affordability, access, and sustainability of Vermont’s Transportation System. Its members are AARP-VT, American Heart Association, American Lung Association in Vermont, CarShare Vermont, CATMA (Chittenden Area Transportation Management Association), Local Motion, Renewable Energy Vermont, Vermont Chapter of the Sierra Club, Vermont Clean Cities Coalition, Vermont Energy Investment Corporation, Vermont Natural Resources Council, and the Vermont Public Interest Research Group.

Summary of Vermont’s Proposal for VW Trust

The Proposed Vermont Beneficiary Mitigation Plan (BMP) for the VW Environmental Mitigation Trust was released November 29 by the Vermont Agency of Natural Resources (VANR). The proposal outlines how Vermont’s allocation of the trust, totaling $18.7 million, will be spent on projects to reduce NOx emissions from mobile sources. The overall goal of the proposal is three-fold:

    1. The first part being to reduce NOx emissions in the most cost-effective way, prioritizing projects that provide the lowest cost per pound of NOx reduced.
    1. The second prong of the goal is to incentivize all-electric or other NOx mitigating alternatively fueled heavy-duty and transit vehicles.
    1. The third prong is to maximize public and private investment in electric vehicle (EV) charging infrastructure by using 15% of its of trust allocation (the maximum allowed under the Trust Agreement).

The majority of proposal’s funds (43%) will be allocated to replace on-road heavy duty diesels with new a diesel or alternative fuel engine. Another 31% of the funding is allocated to replace diesel non-road equipment, such as forklifts and airport ground support, with electric-powered equipment.  This portion of the funding can also be used towards projects under Diesel Emission Reduction Act (DERA), which allows a larger variety of emissions sources and projects to become eligible to apply for funding, such as idle reduction technologies.The plan covers up to 75% of the replacement cost for non-government and up to 100% cost for government equipment and vehicles. Since the plan prioritizes the cheapest NOx reduction per lb. rather than considering life cycle costs, new diesels may rank more competitively than other alternative fuels, unless there is a special carve out for them. The rest of the trust is allocated for light-duty electric vehicle supply equipment (15%) and for locomotives and marine vessels to be repowered with new diesel or alternative fueled engines (11%).

The proposal also gives priority to projects located in areas that receive a disproportionate quantity of air pollution from diesel fleets (e.g. truck stops, rail yards, constructions sites, etc.), and areas that are most vulnerable to negative health impacts of diesel emissions (e.g. schools, medical facilities, etc.). The specific emissions benefits from each eligible category (based on current EPA exhaust emission standards for NOx) are as follows:

    • Heavy duty highway vehicles (examples include eligible large and medium trucks, school buses and transit buses) may provide up to a 96% reduction in NOx emissions per vehicle, based on replacing a model year 1992 diesel engine with a model year 2017 diesel engine.
    • Locomotives, replacing the oldest (Tier 0) engine with the newest (Tier 4) engine may provide up to an 89% NOx reduction per engine.
    • Commercial marine vessels, an upgrade or repower of a ferry engine may provide up to an 80% NOx reduction for each vessel.
    • Non-road equipment (forklifts and airport ground support equipment) replacements may provide up to a 100% reduction in NOx tailpipe emissions per piece of equipment, based on replacing a diesel engine or piece of equipment with an all-electric model.
    • Non-road equipment (under the DERA option) replacements, depending on the type of equipment and engine power rating, may provide between a 20% and 95% reduction in NOx emissions for each engine.
    • EVSE installations will promote the expansion of the electric vehicle market in Vermont by providing the infrastructure critical to the more widespread adoption of these vehicles. This expansion will help to mitigate NOx emitted by the light duty vehicle fleet, which is the largest contributing sector in the state. Exact NOx emissions benefits from each installation will vary, depending on utilization of the installation, the type of vehicles charged and the source of the electricity used to charge the vehicles. Replacing a light-duty passenger vehicle with a Plug-in Hybrid Electric Vehicle (PHEV) or a Battery Electric Vehicle (BEV) may provide a 40 – 76% reduction in NOx emissions.

VTCCC has submitted our official written comments on the proposal. Read our letter to ANR here: VTCCC VW Letter

Update 2/20/2018: In addition to the recommendations made in our letter to ANR, we recommend that any VW monies going towards new diesel or diesel replacement has a bio-diesel warrantied engine up to a B20 blend.