First Name | Ed |
---|---|
Last Name | Pike |
Email Address | epike@energy-solution.com |
Affiliation | Energy Solutions |
Subject | Passenger Vehicle Aftermarket Products Incentive Program |
Comment | PLEASE NOTE: Underline notation for suggested revisions to the draft Investment Plan appear on the submitted PDF version of the comment letter but do not appear when these comments are posted in the "Message" box of the comment submittal web page. The substance of the comments pasted in the "Message" feild are otherwise the same as the attached PDF. April 24, 2013 Chairwoman Mary Nichols California Air Resources Board Sacramento, California Subject: Cap-and-Trade Auction Proceeds Investment Plan – Passenger Vehicle Aftermarket Products Incentive Program Thank you for the opportunity to comment on the draft Cap and Trade Auction Proceeds Investment Plan (or “Investment Plan”) released April 16, 2013. We recommend broadening the Investment Plan’s “Infrastructure” category to encompass additional measures that address the efficiency of the in-use fleet, including fuel efficient replacement tires and engine oil. Such measures were included in the AB32 Scoping Plan, but have not yet been implemented (see p. 51-2 and Appendix C-64). An incentive program in these areas could achieve $750 million in net annual customer savings and reduce greenhouse gases emission by roughly 2 million metric tons, as noted in our February 25 testimony and March 8, 2013 detailed written comments. In addition, a replacement tire incentive program will complement important efforts to potentially develop labeling information and/or standards for low rolling resistance passenger vehicle replacement tires. We suggest the following revision on page B-3 of the Appendix to the draft Investment Plan (proposed additions underlined) to recognize the value of these types of programs: “Infrastructure and Tailpipe Emission Reductions (SB 391): Funding for infrastructure for smooth/GHG pavements [sic], complete streets, ramp meters/traffic management and for vehicle in-use efficiency (such as fuel efficient tires and/or engine oil) programs and incentives.” Thank you for considering our comments. Please contact me or have your staff contact me at epike@energy-solution.com or (510) 482-4420 x239 if you have any questions. Sincerely, Ed Pike, P.E. Senior Project Manager |
Attachment | www.arb.ca.gov/lists/com-attach/287-ghgreductfund13-WjsCZlJgBWRWD1Ix.pdf |
Original File Name | AB32_comments_4-24-13.pdf |
Date and Time Comment Was Submitted | 2013-04-24 11:18:31 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.