Comment Log Display

Dear Ms. Sahota:

Thank you for the opportunity to provide comments in response to
the Public Workshop on the 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.

We recommend explicitly including the benefits of fuel efficient
passenger vehicle replacement tires in ARB’s policy scenarios,
emissions calculations, and economic modeling. Currently,
replacement tires are substantially less efficient than tires on
new vehicles and would undermine a significant portion of the
expected emissions and economic benefits of GHG standards for
passenger vehicle as they age and are equipped with replacement
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 will 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 appreciate your consideration of our comments. Please feel free
to contact me or have your staff contact me at
epike@energy-solution.com or (510) 482-4420 x 239 if you wish to
discuss our comments.

Sincerely,

Ed Pike, P.E.
Senior Engineer