Comment Log Display

May 23, 2016

Mary Nichols, Chair
California Air Resources Board
1001 I Street
Sacramento, CA 95814
 
RE: FY 2016-17 Funding Plan for Low Carbon Transportation and Fuels
Investments and the Air Quality Improvement Program (AQIP)

Dear Chair Nichols and Board Members,

We appreciate the opportunity to provide comments on the Fiscal
Year 2016-2017 Low Carbon Transportation and Fuels Investments and
the Air Quality Improvement Program (AQIP). Green Commuter strongly
supports staff’s proposed recommendations for the overall Low
Carbon Transportation Funding Plan and specifically for Light-Duty
Pilot Projects to Benefit Disadvantaged Communities. These programs
are essential to accelerate widespread commercial deployment of
zero emission vanpools, car sharing, and fleet replacement to
substantially reduce greenhouse gas emissions, alleviate traffic
and decrease the cost of commuting. 

Green Commuter has developed an innovative system to utilize a
fleet of 100% zero emission vehicles to provide a combined service
of vanpool and fleet replacement to help decrease the cost of
commuting, alleviate traffic, and reduce greenhouse gas emissions.
To maximize vanpool efficiency, Green Commuter created a new model
to use the vanpool vehicle to both transport passengers to and from
employment centers and replace an employer’s fleet during the
middle of the day.  The efficiency between the two systems
dramatically increases the benefits and helps reduce costs. The
Green Commuter system will help accelerate zero emission vanpool
and fleet replacement to reduce air pollution, improve conditions
in disadvantaged communities, improve connectivity, alleviate
traffic congestion, and help carry out the Governor’s ZEV Action
Plan for 1.5 million vehicles on the road by 2025. 

Our specific comments are outlined below: 

1.	Support for Funding Plan and Suggestion for Expansion of
Existing Project Categories 
Green Commuter supports staff’s overall proposed Low Carbon
Transportation Funding Plan for $500 million for FY 2016-2017. If
ARB receives additional funding for Low Carbon Transportation from
California Climate Investments, we support allocating further
funding for Light-Duty Pilot Projects to Benefit Disadvantaged
Communities, as many of these programs have been significantly
oversubscribed. Specifically, we support including a Zero emission
Vanpool category within the Light-Duty Pilot Projects to Benefit
Disadvantaged Communities, similar to the category for Agricultural
Worker Vanpools in order to help deploy zero emission vanpool
vehicles in disadvantaged communities throughout the state. 


2.	Support for Car Sharing and Mobility Options Program 
Green Commuter strongly supports the Car Sharing and Mobility
Options program and the $8M proposed for the FY 2016-2017 Funding
Plan. We suggest also including the $300,000 from last year’s award
that is no longer moving forward into the FY 2016-2017 Car Sharing
and Mobility Options program, as those funds were intended to help
deploy projects within this category. This funding is essential to
help deploy zero emission car sharing and vanpooling to
disadvantaged communities in California.

3.	Support for incentizing EV leasing and EV rental arrangements
Currently, many of the State’s EV investments and associated
incentives typically have not been applied to EV leasing and EV
rental arrangements.  EV leasing and rental arrangements are an
optimal model for fleet, car sharing, and vanpool applications. 
They offer an attractive option to government agencies, transit
operators, and other fleet operators to efficiently deploy zero
emission vehicles, without additional burdens of dealing with
maintenance, insurance, etc.  The convenience and economy of scale
offered by the leasing and rental option, in turn, increases the
scale and speed at which fleets are able to transform to zero
emission technologies.   

Thank you again for the opportunity to provide comments the Low
Carbon Transportation and AQIP Funding Plan. We appreciate the
leadership of the California Air Resources Board and the hard work
to the entire AQIP team to reduce greenhouse gas emissions to
benefit communities throughout California. 

Kind Regards,

Gustavo Occhiuzzo 
CEO

Johanna Vandemoortele
Director of Grants and Partnerships