Comment Log Display

Thank you for the opportunity to provide comments on the Discussion
Draft 2030 Target Scoping Plan Update.  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 ARB’s innovative and critical work to reduce greenhouse gas
(GHG) emissions.

As noted in our attached letter, we recommend explicitly including
the benefits of fuel efficient passenger vehicle replacement tires
in the discussion draft list of measures and in the upcoming
appendix detailing the emissions calculations. Currently,
replacement tires offered on the market are generally substantially
less efficient than tires factory-installed on new passenger
vehicles. Therefore, a significant portion of the expected
emissions and economic benefits of GHG standards for passenger
vehicles would be undermined as factory-installed tires are
replaced with less efficient tires. 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
AB32 Scoping Plan Update). 

A 10% improvement in replacement tire efficiency would reduce GHG
by 2.7 million metric tons and save consumers $882 million annually
according to the California Energy Commission.  A study  for the
South Coast Air Quality Management District demonstrates that 20%
or greater improvement is feasible and will especially benefit air
quality in disadvantaged communities where used vehicles operating
on replacement tires are more common. We also estimate  that the
average driver will save up to $1000 in fuel costs.

We recommend the following specific revision to the transportation
section of the discussion draft:

“Known commitments: 
…
Implement the original scoping plan light duty passenger vehicle
replacement tire rolling resistance measure (page C-62) and meet AB
844 ‘Replacement Tire Efficiency Program’ goals.”

We also recommend addressing fuel efficient replacement tires for
light duty vehicles in the upcoming appendix detailing GHG emission
calculations. Without fuel efficient replacement tires, new light
duty vehicle GHG emissions will increase by several million metric
tons annually when tires are replaced. 

We appreciate your consideration of our comments.