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Comment 51 for Volkswagen Environmental Mitigation Trust for California (vw-mititrust-pl-ws) - 1st Workshop.


First Name: Michael
Last Name: Rea
Email Address: mikerea22@gmail.com
Affiliation: CASTO and School Transportation Coalitio

Subject: School Bus Replacement with the VW Mitigation Trust Funds
Comment:
I attended and shared some verbal comments at the workshop meeting
in Sacramento on Monday February 26.  Here is the content of my
comments as well as some others:

1.  School transportation providers in California are extremely
grateful for the long partnership between CARB and school
transportation providers in California.  Without ongoing funding
like the Lower Emission School Bus Program and your support through
the years, we would not have been able to replace older buses with
newer, cleaner school buses.

2.  By the CARB's own research as well as other research in the
late 1980's and early 1990's, our children and youth are most
vulnerable to the poor air quality inside the bus they are riding,
which is often dirtier than the air outside the bus.  Older buses
had far more tailpipe emissions, and since most of them were
diesel, had much higher particulate matter content.

3.  Your staff recommendation for $130 of the VW mitigation trust
to be applied to public transit, shuttle buses and school bus is a
sizeable amount.  For that, we are most grateful.  

We would strongly advise, however, that specific amounts are
articulated for each mode.  Of these three modes of transportation,
Public Transit often has other resources, to include FTA funding
for bus replacement.  Shuttle can also include paratransit, which
also benefits from FTA funding.  We would strongly encourage that
CARB supports a higher allocation for school bus, as school
districts, JPAs and County offices of education have no other
sources, and have been severely underfunded for school
transportation (and general education) for years.  You can barely
go a day without reading an article in a newspaper or media source
somewhere in California where school districts are cutting their
budgets because the funding they receive, even to educate, is not
enough.  We would strongly urge a separate appropriate for school
bus replacement that is near $100 million.

Although, that seems like a lot, school buses represent the largest
fleet of publicly supported transportation in the State, with over
24,000 school buses. 
 
By your estimates in the proposal, there are close to 4,500 school
buses that would be eligible for such funding.  With electric buses
costing nearly $400,000, $100 million would only fund 250 school
buses, no where near addressing the overall need.

4.  In addition to no tailpipe emissions with the new school buses,
there would also be an additional safety benefit, as all the new
school buses would be outfitted with three point seat belts.  Older
buses do not have seat belts.  State law required that all new
buses purchased since 2006 must have the three-point seat belts.

5.  We also encourage that CARB utilize competitive criteria that
has been cooperatively developed over the years for school bus
replacement programs.  It is based on age of the bus and mileage
and would ensure that the oldest buses are replaced first.

We believe this is another reason why there should be separate and
articulated amounts for shuttle and transit buses, because they
would most likely be working with very different criteria, and it
would not appropriate and beneficial to mix the types of buses. 
For example, you might want to see public transit criteria that
stipulated a local or FTA contribution of a portion of the funds. 
Comparing school bus to those other types of buses in a competitive
criteria environment would most likely not benefit school bus
replacement, or our most vulnerable population, our children and
youth.

Thank you for your support of school bus replacement over the
years!  We are truly appreciative.

Mike Rea

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Date and Time Comment Was Submitted: 2018-02-28 13:34:06



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