Comment Log Display

Dear Chair Nichols:

Thank you for the opportunity to provide comments on the proposed
2017 Climate Change Scoping Plan Update (Scoping Plan Update). We
have provided these comments via the online ARB comment field, and
via a similar attached letter. 

Energy Solutions is a professional and engineering services firm
whose mission is to create large-scale environmental impacts by
providing market-based, cost-effective energy, carbon, and water
management solutions to our utility, government and commercial
customers. We strongly support the innovative and critical
leadership from the Air Resources Board (ARB) in reducing
greenhouse gas (GHG) emissions in California.
 
We recommend adding fuel-efficient passenger vehicle replacement
tires to the list of transportation measures and to the Appendix F
Environmental Analysis. Replacement tires offered on the market
typically lead to a four percent increase in GHG and other
emissions compared to tires fitted on new vehicles. Using baseline
emissions from CARB’s EMFAC2014 model, fuel efficient replacement
tires will reduce GHG by more than two million metric tons per year
through 2030. This quantity of GHG is cumulatively equal to more
than 15% of the proposed cumulative reductions from additional
transportation measures, including refineries, through 2030. 

Fortunately, ARB has found that “fuel efficient passenger vehicle
tires can be utilized by both new and in-use vehicles in the
near-term to achieve GHG emission reductions. Deployment of fuel
efficient vehicle tires for in-use vehicles could include limited
incentives, followed by ratings and then standard setting to
permanently shift the market” (May 2014 First Update to the Climate
Change Scoping Plan). 

We strongly agree. A study for the South Coast Air Quality
Management District finds that disadvantaged communities where
vehicles operating on replacement tires are more common will
particularly benefit from air quality and economic benefits. Based
on that study, drivers will save up to $1000 in fuel costs over the
lifetime of their vehicle. 

We recommend the following addition to section IV.C of the proposed
Scoping Plan Update:

“Persistent market barriers such as the lack of customer
information and standards have led to a significant efficiency gap
between tires shipped with new light duty vehicles and tires
available in the replacement market. A study for South Coast AQMD
estimates that a 4% average vehicle fuel efficiency improvement can
be achieved through improved efficiency of replacement tires,
resulting in very cost-effective air quality and GHG benefits and
major consumer benefits.  This study is also consistent with
research for ARB and CalEPA, an earlier study by the National
Research Council, and research demonstrating the effectiveness of
the European Union (EU) program in closing this gap. 

The resulting air quality and economic benefits are especially
important for lower income and disadvantaged communities where
older, higher emitting vehicles that use replacement tires are more
prevalent. The prior 2014 Scoping Plan Update highlights policies
such as incentives, consumer information and standards to overcome
persistent market barriers to fuel efficient replacement tires and
unlock these benefits.

While the federal government has not implemented a program to
improve the rolling resistance of light duty vehicle replacement
tires, California has a timely opportunity to move forward and
achieve the replacement tire efficiency goals in AB 844 (Nation,
2003).  California can leverage metrics and lessons learned in the
EU, Japan and South Korea and collaborate with Canadian efforts to
develop a tire efficiency program.” 
 
We also recommend the following addition to the Transportation
Sustainability “On-going and proposed measures – vehicle
technology” sub-section IV.C.3:

“Improve light duty vehicle fuel economy for passenger vehicles by
4% through policies that achieve fuel efficient replacement tires
and achieve the goals of AB 844 (Nation 2003).”

We appreciate your consideration of our comments. Please feel free
to contact Ed Pike of my staff or have your staff contact him at
epike@energy-solution.com or (510) 482-4420 x 239 if you have any
questions.

Sincerely,

 
Mike McGaraghan
Director
Energy Solutions