July 28, 2016
We are writing to request your support to ensure that the final settlement between the U.S. government and Volkswagen provides maximum flexibility for States and Native American tribes to allocate funds to the most cost effective strategies for reducing diesel emissions within their communities. Specifically, we are asking you to submit a formal comment to the U.S. Justice Department on the draft settlement agreement urging the parties to expressly list truck stop electrification (TSE) as an “Eligible Mitigation Action” under Appendix D-2 of the agreement. The deadline for comments is August 5, 2016.
In short, the U.S. Department of Transportation and Environmental Protection Agency rank truck stop electrification as the single most cost effective method of mitigating diesel emissions from mobile sources. It is also the best method of mitigating air pollution at truck stops and fleet terminals, which tend to be located in disadvantaged communities.
Below we provide more details on the issue, a sample comment letter, and directions for where to submit the comments. You can also submit a convenient form letter to the Department of Justice through our website.
The draft settlement agreement includes a $2.7 billion mitigation fund, which will enable the States and Indian Tribes to invest in various projects, technologies, and activities that will help reduce NOx emissions caused by diesel engines. Unfortunately, the proposed agreement fails to expressly list truck stop electrification as an eligible mitigation action that can receive investments from the States and Tribes. This is despite the fact that overnight idling by diesel trucks is a major source of NOx pollution, which has a disproportionate impact on disadvantaged communities where most truck stops and fleet terminals tend to be located (the population within 1.5 miles of Texas’ 15 IdleAir Locations consists of 65% more minorities and a per capita income 24% lower than the statewide average). EPA’s Diesel Emission Reduction program flags the communities surrounding truck stops for programmatic priority. Moreover, the Federal Highway Administration rates truck stop electrification (idle reduction) as the #1 cost effective solution to mitigate NOx emissions, at $2k/ton of NOx.
Figure 3. Median Cost-Effectiveness Estimates (Cost per Ton Reduced) of NOx Emission Reductions. Entire report can be found here and select pages here. See also EPA report specifically scoring TSE as the most cost effective on page 13 at median $1.7k/ton of NOX (scoring diesel retrofit at a median cost of $5,950/ton of NOX).
We note that this report, while published in 2007, is the most recent EPA analysis on point. Total installation costs for IdleAir, the company informing the data, has decreased by around 50% from the stated assumptions. We also note that sales data demonstrates that even better cost effectiveness can be achieved if limited vouchers are distributed to truck drivers for higher utilization of existing infrastructure during this period of relatively inexpensive fuel.
Most people are unaware that over a million heavy duty diesel trucks idle for about 40% of engine run time because drivers who sleep in their cabs are unable to heat or cool their home away from home without idling a 500HP diesel engine. (Huai, T., et al., 2006. “Analysis of heavy-duty diesel truck activity and emissions data,” Atmospheric Environment, 40, 2333-2344) (See also https://youtu.be/3oLsyLHUNqA) The Argonne National Laboratory estimates that rest-period idling results in the emission of about 11 million tons of carbon dioxide, 55,000 tons of nitrogen oxides (NOx), and 400 tons of particulate matter released annually in the U.S. See the report here.
IdleAir and Shorepower Technologies, two verified providers from the EPA SmartWay Verified List of Idle Reduction Technologies, operate a combined network over 3500 electrified truck parking spaces nationwide. Heavy duty zero emission supply equipment is known under the EPA SmartWay program as Electrified Parking Spaces or Truck Stop Electrification. EPS/TSE uses electricity-powered components to provide the operator with climate control and auxiliary power without having to idle the main engine. The IdleAir network last year alone saved drivers over a million gallons of diesel fuel and reduced total diesel emissions by a verified 11,330 metric tons (60mt of CO, 11,114mt of CO2, 144mt of NOX, 4mt of PM and 7.3mt of VOC).
Although the proposed Mitigation Action Plan includes a provision for a DERA Option for actions not specifically enumerated in Appendix D-2, we are concerned that this catchall provision is inadequate for several reasons. Primarily, States and Tribes are likely to choose direct assistance to enumerated technologies, not because they are superior, but to avoid the administrative burden of the DERA program. In fact, some States currently decline to participate in DERA altogether. Moreover, should Congress decide not to provide funding for the DERA program, there would be no opportunity to invest settlement funds in TSE.
Our “ask” is to specifically list TSE as an Eligible Mitigation Action in Appendix D-2, in addition to the nine currently listed actions, i.e. diesel retrofit and ocean vessel shorepower. TSE delivers local air quality benefits with zero emissions at the point of use. The language can mirror that of “Option 9” for light duty electric charging infrastructure, and provide vouchers for truck drivers to increase the number of truckers using existing truck stop electrification facilities.
Please respond to the notice of public comment by the deadline of August 5th, by emailing email@example.com, with a subject line of “In re: Volkswagen “Clean Diesel” Marketing, Sales Practices, and Products Liability Litigation,Case No: MDL No. 2672 CRB (JSC), and D.J. Ref. No. 90-5-2-1-11386,” and ask that Truck Stop Electrification be listed as an enumerated technology. Feel free to copy and paste some or all of the content in the sample letter below under your own letterhead. You can also submit a convenient form letter to the Department of Justice through our website.
Convoy Solutions LLC
Proud Providers of the IdleAir System
629 North Broadway
Knoxville, TN 37917
SAMPLE COMMENT LETTER