With your help, these funds could be used to build more TSE locations or even create vouchers that give free or discounted service.

John C. Cruden Esq.
Assistant Attorney General
Environment and Natural Resources Division
U.S. Department of Justice

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.

Dear Mr. Cruden:

Our organization writes to request that the final settlement between the U.S. government and Volkswagen provide maximum flexibility for States and Native American tribes to consider allocating some of their funds to truck stop electrification (TSE). Specifically, we ask that the settlement expressly list truck stop electrification as an eligible mitigation activity within Appendix D2, along with the nine other activities that already include various forms of diesel retrofits and the marine equivalent of truck stop electrification. While TSE is eligible for funding under the DERA program option, we are concerned that some States and Tribes will decline or minimize use of the DERA option. Moreover, should Congress decide not to provide funding for the DERA program, there would be limited opportunity to invest in TSE.

Too often, drivers idle their engines during overnight stays in order to maintain a safe and comfortable interior environment. The practice takes place on a large scale and has a disproportionate impact on disadvantaged communities where truck stops and fleet terminals tend to be located. DERA’s own guidelines flag the communities surrounding truck stops for programmatic priority. The Argonne National Laboratory estimates that rest-period idling wastes about 1B gallons of diesel and results in the emission of about 55,000 tons of nitrogen oxides released annually in the US. The EPA rates Truck Stop Electrification as the single most cost effective activity to mitigate mobile sources of NOX emissions (less than one third of the cost per ton achieved through diesel retrofits). See page 13. Truck Stop Electrification, an EPA SmartWay verified technology, provides long-haul truck drivers an alternative to idling their diesel engines during their overnight stays. Significant NOX mitigation can be achieved through 1) installation of new TSE locations; and 2) TSE vouchers for truck drivers to encourage more truckers to use existing TSE facilities.

Again, we urge you to specifically list TSE infrastructure and TSE vouchers as eligible mitigation activities under Appendix D2 of the settlement. This would afford beneficiaries maximum flexibility to achieve the settlement’s goal of improving air quality in disadvantaged communities by reducing harmful diesel emissions.

Thank you for your consideration.

Sincerely,